United States v. Daly’s Empirical Analysis
481 F.2d 28 · 1973
Citation profile
75 federal appellate · 5 district · 9 state decisions
How this case has been cited
Cited by 193 later decisions — most recently May 2017 · most notably Gajewski v. Commissioner (1976), Cupp v. Commissioner (1975)
75 federal appellate · 5 district · 9 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 26 U.S.C. § 7203
Relies on United States v. Sullivan · California v. Byers · Florsheim Bros. Drygoods Co. v. United States · Lovell Manufacturing Co. v. Etten · United States v. Porth
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 193 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] taxpayer's return which does not contain any information relating to the taxpayer's income from which the tax can be computed is not a return within the meaning of the Internal Revenue Code or the regulations adopted by the Commissioner.”
4 later decisions quote this exact passage · from the majority“It belabors the obvious to point out that the purpose of the tax laws is to raise public funds, that adequate operation of the taxing procedures is vital to the well-being of this country, and that the basic purpose of the tax laws is not to punish extraneous crimes but to assess and collect revenue. Offenses for violations of the tax laws are, of course, set up as a necessary enforcement measure. Our income tax system is to a large extent predicated upon the voluntary disclosure of taxable income. The operation of this system is of crucial concern to the nation. The public need for requiring voluntary disclosures of income transcends any personal right to thwart national objectives by allowing an undisclosed self-determination of possible incrimination, thus excusing compliance with the income tax laws. We, therefore, hold that the Fifth Amendment privilege against incrimination does not extend to defendant's failure to file or cause to be filed the corporate tax returns * * *.”
2 later decisions quote this exact passage · from the majority“most of which are innocuous on their face.”
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.