Commissioner v. Acker’s Empirical Analysis
1959
Citation profile
359 federal appellate · 27 district · 41 state decisions
How this case has been cited
Cited by 738 later decisions (20 by the Supreme Court) — most recently June 2026 · most notably Leary v. United States (1969), Flora v. United States (1960)
359 federal appellate · 27 district · 41 state decisions — followed in 15 states
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.
Appellate journey
reviewedAcker v. Commissioner of Internal Revenue (from Sixth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 58 · 26 U.S.C. § 6654
Relies on Manhattan General Equipment Co. v. Commissioner of Internal Revenue · Boston Sand & Gravel Co. v. United States · Koshland v. Helvering · Federal Communications Commission v. American Broadcasting Co.
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 738 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“penal statutes are to be construed strictly,”
13 later decisions quote this exact passage · from the majority“task is to construe not English but congressional English.”
5 later decisions quote this exact passage · from the dissent““But the section contains nothing to that effect, and, therefore, to uphold this addition to the tax would be to hold that it may be imposed by regulation, which, of course, the law does not permit. United States v. Calamaro, 354 U.S. 351 , 359, [ 77 S.Ct. 1138 , 1143, 1 L.Ed.2d 1394 ]; Koshland v. Helver-ing, 298 U.S. 441 , 446-447, [ 56 S.Ct. 767 , 769-770, 80 L.Ed. 1268 ]; Manhattan [General Equipment] Co. v. Commissioner [of Internal Revenue], 297 U.S. 129 , 134, [ 56 S.Ct. 397 , 399, 80 L.Ed. 528 ].””
4 later decisions quote this exact passage · from the majority
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.