← 458 F.2d 953 - In the Matter of Abner Michaud and Alyce E Michauds Appeal of United States of America

In the Matter of Abner Michaud and Alyce E Michauds Appeal of United States of America’s Empirical Analysis

Citation profile

cited by 5 later decisions

February 1981

most recently cited

1 federal appellate ·

Relationships

Applies 26 U.S.C. § 6213 · 26 U.S.C. § 6501 · 26 U.S.C. § 6861

Relies on Banks v. Chicago Grain Trimmers Assn., Inc. · SWARB Et Al. v. LENNOX Et Al. · Germantown Trust Co. v. Commissioner · Colony, Inc. v. Commissioner · United States v. Speers

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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“the phrase “taxes . . . which were not reported on a return made by the bankrupt” as used in Section 17(a)(1)(c) of the Bankruptcy Act includes a tax deficiency ultimately established by the Government even if, as in [this case], the taxpayer has fully reported both his gross income and the basis of the deductions which are ultimately disallowed.”
2 later decisions quote this exact passage · from the majority
e.g. Donnell v. Commissioner · In Re the Matter of Ned H. Donnell, AKA Ned Halcomb Donnell, Bankrupt. Ned H. Donnell v. Commissioner of Internal Revenue Service
“It is anomalous to say that under proviso (b) a taxpayer-bankrupt may be released from tax liability arising from the failure of the bankrupt to make a return required by law where the taxes became legally due and owing more than three years before bankruptcy and were assessed more than one year before filing of the petition, and to interpret proviso (c) in such a way that a deficiency arising from a return made by a bankrupt in which there was full disclosure, will not be released, although the taxes became legally due and owing more than three years before bankruptcy.”
1 later decision quote this exact passage · from the majority
e.g. 396 F. Supp. 141 - In Re Wukelic

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.