Marcello v. Commissioner’s Empirical Analysis
1964
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 335 later decisions — most recently June 2020 · most notably Freytag v. Commissioner (1987), Jackson v. Commissioner (1972)
3 federal appellate ·
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. § 1202 · 26 U.S.C. § 6653
Relies on Cohan v. Commissioner · Pinellas Ice & Cold Storage Co. v. Commissioner · Schroeder v. Commissioner · Commissioner of Internal Revenue v. Union Pac. R. Co. · Ennis v. Commissioner
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 335 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Inasmuch as part of the underpayment of tax is due to negligence, the addition to tax under section 6653(a) must be imposed on the entire amount of such underpayment.”
1 later decision quote this exact passage
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.