Wild v. United States’s Empirical Analysis
362 F.2d 206 · 1966
Citation profile
46 federal appellate · 6 district · 2 state decisions
How this case has been cited
Cited by 82 later decisions (1 by the Supreme Court) — most recently July 1982 · most notably Donaldson v. United States (1971), Roberts v. Commissioner (1974)
46 federal appellate · 6 district · 2 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
Applies 26 U.S.C. § 7602 · 26 U.S.C. § 7604
Relies on United States v. Powell · Reisman v. Caplin · Boren v. Tucker · Magnus Mabee Reynard Inc Hurdman Cranstoun
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * -x- * if the sole objective of an investigation is to obtain evidence for use in a criminal prosecution, the purpose is not legitimate and enforcement should be denied. See Reisman v. Caplin, 375 U.S. 440, 449 , 84 S.Ct. 508 , 11 L.Ed.2d 459 . “If, however, the objective cf. the investigation is to obtain information which may be utilized in determining whether there is civil liability for a tax or a tax plus penalty, then the summons may be enforced notwithstanding the fact that the information might also be used in a criminal prosecution. See Boren v. Tucker, 9 Cir., 239 F.2d 767, 772-773 ; Sanford v. United States, 5 Cir., 358 F.2d 685 ; In re Magnus, Mabee & Raynard, Inc., 2 Cir., 311 F.2d 12, 16 .” 362 F.2d at 208-209 .”
4 later decisions quote this exact passage · from the majority“developing information concerning alleged criminal violations thereof, evaluating allegations and indications of such violations to determining investigations to be undertaken, investigating suspected criminal violations of such laws, recommending prosecution when warranted, and measuring effectiveness of the investigation and prosecution processes.”
2 later decisions quote this exact passage · from the majority““* * * Appellants had all the procedural rights they were entitled to under the Federal Rules of Civil Procedure, including an opportunity to answer, which they did, and a hearing. No prejudice has been claimed or shown.””
1 later decision 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.