Smith v. Commissioner’s Empirical Analysis
1960
Citation profile
4 federal appellate · 1 state decisions
How this case has been cited
Cited by 27 later decisions — most recently January 2002 · most notably Newsome v. United States (1970), Medeiros v. Commissioner (1981)
4 federal appellate · 1 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Tank Truck Rentals, Inc. v. Commissioner · Bloom v. United States · United States v. Chouteau · Hoover Motor Express Co. v. United States · Jerry Rossman Corp. v. Commissioner
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“bespeaks this intent. Thus, the assessment of liability under section 2707(a) is not an automatic administrative action where an employer fails to pay its taxes. To the contrary, liability is imposed only in those instances where there is a willful failure to act by the particular officer, employee, or partner charged with the duty to act, or where such person”
1 later decision quote this exact passage“(Emphasis supplied). Such willful failure to act, or attempt to evade or defeat the tax, is referred to in section 2707(d) as a”
1 later decision quote this exact passage“the allowance thereof would frustrate the public policy”
1 later decision quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.