United States v. Porth’s Empirical Analysis
426 F.2d 519 · 1970
Citation profile
100 federal appellate · 5 district · 8 state decisions
How this case has been cited
Cited by 279 later decisions — most recently April 2011 · most notably Gajewski v. Commissioner (1976), Edwards v. Commissioner (1982)
100 federal appellate · 5 district · 8 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 Brushaber v. Union Pacific Railroad · Commissioner v. Acker · Interstate Circuit, Inc. v. City of Dallas · Michigan National Bank v. Michigan · Florsheim Bros. Drygoods Co. 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 279 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“information relating to the taxpayer's income from which the tax can be computed.”
20 later decisions quote this exact passage · from the majority“The indictment in counts 1 and 2 charges a “willful” failure “to truthfully account for and pay over” to the Internal Revenue Service FICA and general income taxes withheld from wages. Count 3 alleges that Porth “willfully” failed to make an individual income tax return, and counts 4 and 5 allege a willful failure to file quarterly federal returns for the FICA taxes which the statute required to be withheld. These offenses are clearly within the six-year exception to the general three-year statute of limitations of § 6531. Waters v. United States, 328 F.2d 739 (10th Cir. 1964) (other cites omitted). (at 521-22).”
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.