Webb v. Commissioner’s Empirical Analysis
1968
Citation profile
93 federal appellate · 2 state decisions
How this case has been cited
Cited by 659 later decisions — most recently January 2020 · most notably Rowlee v. Commissioner (1983), Petzoldt v. Commissioner (1989)
93 federal appellate · 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. § 165
Relies on Welch v. Helvering · Holland v. United States · Commissioner of Internal Revenue v. Duberstein D Stanton · Helvering v. Taylor · 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 659 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“circumstances which at most create only suspicion.”
18 later decisions quote this exact passage · from the majority““We recognize that the absence of adequate tax records does not give the Commissioner carte blanche for imposing Draconian absolutes. [Citations omitted.] But such absence does weaken any critique of the Commissioner’s methodology. [Citations omitted].””
12 later decisions quote this exact passage · from the majority“[Tjhe absence of adequate tax records does not give the Commissioner carte blanche for imposing Draconian absolutes ____ [However,] such absence does weaken any critique of the Commissioner’s methodology. Arithmetic precision was originally and exclusively in [the taxpayer’s] hands, and he had a statutory duty to provide it____ [Hjaving defaulted in his duty, he cannot frustrate the Commissioner’s reasonable attempts by compelling investigation and reeomputation under every means of income determination. Nor should he be overly chagrined at the Tax Court’s reluctance to credit every word of his negative wails.”
11 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.