Shomaker v. Commissioner’s Empirical Analysis
1962
Citation profile
4 federal appellate · 1 state decisions
How this case has been cited
Cited by 84 later decisions — most recently April 2013 · most notably Pritchett v. Commissioner (1974), Estate of Reynolds v. Commissioner (1970)
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
Applies 26 U.S.C. § 1 (Airport and Airway Extension Act of 2008) · 26 U.S.C. § 6651 · 26 U.S.C. § 71
Relies on Helvering v. Horst · Brushaber v. Union Pacific Railroad · Corliss v. Bowers · Gould v. Gould · Costello 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 84 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Addition to the Tax. — In case of failure— (1) to file any return required under authority of subchapter A of chapter 61 (other than part III thereof), of subchapter A of chapter 51 * * * on the date prescribed therefor (determined with regard to any extension of time for filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the amount required to be shown as tax on such return 5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate.”
2 later decisions quote this exact passage · from the majority“due to reasonable cause and not due to willful neglect.”
2 later decisions quote this exact passage · from the majority“taxpayers who deliberately omit to file returns must use reasonable care to ascertain that no returns are necessary, and that in the absence of obtaining competent advice, the mistaken belief on the part of a taxpayer that no return was required under the statute does not constitute reasonable cause for noncompliance.”
1 later decision quote this exact passage · from the majoritye.g. Thorne v. Comm'r
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.