United States v. Tunnell’s Empirical Analysis

Citation profile

22 federal appellate ·

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

1. “In a typical net worth prosecution, the Government, having concluded that the taxpayer's records are inadequate as a basis for determining income tax liability, attempts to establish an 'opening net worth' or total net value of the taxpayer's assets at the beginning of a given year. It then proves increases in the taxpayer's net worth for each succeeding year during the period under examination and calculates the difference between the adjusted net values of the taxpayer's assets at the beginning and end of each of the years involved. The taxpayer's nondeductible expenditures, including living expenses, are added to these increases, and if the resulting figure for any year is substantially greater than the taxable income reported by the taxpayer for that year, the Government claims the excess represents unreported taxable income.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Skalicky

2. “The requisite affirmative act can be found in the filing of false tax returns for each year in the indictment.”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Hughes