Edwards v. United States’s Empirical Analysis
375 F.2d 862 · 1967
Citation profile
38 federal appellate · 2 district ·
How this case has been cited
Cited by 48 later decisions (1 by the Supreme Court) — most recently April 2015 · most notably United States v. Bishop (1973), Herbert W. Dustin and Kathleen C. Dustin v. Commissioner of Internal Revenue (1972)
38 federal appellate · 2 district ·
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. § 6651 · 26 U.S.C. § 7201 · 26 U.S.C. § 7203 · 26 U.S.C. § 7206
Relies on Spies v. United States · Sansone v. United States · United States v. Murdock · Abdul v. United States · Wilson v. United States
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“proof of willfulness in the sense of a specific intent to evade or defeat the tax or its payment.”
2 later decisions quote this exact passage · from the majority“It thus appears that appellant’s purpose was to take advantage of the time lag in Government investigation of delinquent returns to tide him over during a period of personal financial hardship. Nothing in the record would, suggest that he ever intended the permanent evasion of any of his clients’ taxes. One pursuing a path such as that of appellant might eventually fall so far behind that no reasonable man could believe that he would ever catch up. It does not appear, however, that appellant’s straits had become that serious.”
1 later decision quote this exact passage · from the majority“Any person who willfully attempts in any manner to evade or defeat any tax imposed by this title or the payment thereof shall, in addition to other penalties provided by law, be guilty of a felony and, upon conviction thereof, shall be fined not more than $10,000, or imprisoned not more than 5 years, or both, together with the costs of prosecution.”
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.