United States v. Robson’s Empirical Analysis
477 F.2d 13 · 1973
Citation profile
29 federal appellate · 7 district · 5 state decisions
How this case has been cited
Cited by 51 later decisions (1 by the Supreme Court) — most recently September 2020 · most notably Beckwith v. United States (1976), United States v. Little (1984)
29 federal appellate · 7 district · 5 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 18 U.S.C. § 3731 · 26 U.S.C. § 7201
Relies on United States Accardi v. Shaughnessy · Gouled v. United States · Mathis v. United States · United States v. Heffner · United States v. Prudden
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] revenue agent must not affirmatively mislead a taxpayer into believing that the investigation is exclusively civil in nature and will not lead to criminal consequences.”
2 later decisions quote this exact passage · from the majority“Assuming arguendo that the failure of the IRS to follow its procedures designed to protect the rights of taxpayers amounts to a violation of due process under the principle ¡of United States ex rel. Accardi v. Shaughnessy, 347 U.S. 260 , 74 S.Ct. 499 , 98 L.Ed. 681 (1954), 4 we find nothing in the record before us indicating that Koba was an agent of the Intelligence Division. 477 F.2d at 17 .”
1 later decision quote this exact passage · from the majority“the failure of an IRS agent. . . to warn a taxpayer that[a civil] audit may have potential criminal ramifications does not render the search unreasonable.”
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.