Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal Revenue’s Empirical Analysis
1967
Citation profile
25 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 556 later decisions — most recently September 2021 · most notably Neely v. Commissioner (1985), Freytag v. Commissioner (1987)
25 federal appellate · 2 district · 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 Welch v. Helvering · New Colonial Ice Co. v. Helvering · Helvering v. Taylor · Cohan v. Commissioner · Helvering v. Mitchell
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 556 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“lack of due care or failure to do what a reasonable and ordinarily prudent person would do under the circumstances.”
260 later decisions quote this exact passage · from the majority“If any part of any underpayment * * * is due to negligence or intentional disregard of rules and regulations * * * there shall be added to the tax an amount equal to 5 percent of the underpayment.”
17 later decisions quote this exact passage · from the majority“negligence or intentional disregard of rules and regulations”
8 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.