Acker v. United States’s Empirical Analysis
1981
Citation profile
7 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 15 later decisions — most recently May 2012
7 federal appellate · 1 district · 1 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. § 6402 · 26 U.S.C. § 6511 · 26 U.S.C. § 6513 · 26 U.S.C. § 6621 · 26 U.S.C. § 6651 · 26 U.S.C. § 6653 · 26 U.S.C. § 7203 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on United States v. Radio Television News Directors Ass'n · United States v. Bornstein · H. K. Porter Co. v. National Labor Relations Board · Commissioner v. Acker · Stoltzfus v. United States
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the case of any overpayment, the Secretary, within the applicable period of limitations, may credit the amount of such overpayment, including any interest allowed thereon, against any liability in respect of an internal revenue tax on the part of the person who made the overpayment and shall, subject to subsections (c) and (d), refund any balance to such person. [Emphasis supplied.]”
2 later decisions quote this exact passage · from the majority“(b) Fraud. — If any part of any underpayment ... of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment ....”
2 later decisions 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.