Howard B. Quinn and Charlotte J. Quinn v. Commissioner of Internal Revenue’s Empirical Analysis
1975
Citation profile
47 federal appellate · 1 state decisions
How this case has been cited
Cited by 151 later decisions — most recently September 2020 · most notably Purcell v. Commissioner (1987), Stevens v. Commissioner (1989)
47 federal appellate · 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 18 U.S.C. § 657
Relies on James v. United States · North American Oil Consolidated v. Burnet · Burnet v. Sanford & Brooks Co. · Dixon v. Unied States · Spring City Foundry Co. v. Commissioner
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 151 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As the Seventh Circuit stated: ‘[t]he knowledge contemplated by [section 6013(e)] is not lmowledge of the tax consequences of a transaction but rather knowledge of the transaction itself.’”
9 later decisions quote this exact passage · from the majority“(e) Spouse relieved of liability in certain cases— (1) In general — under rules prescribed by the Secretary, if— (A) a joint return has been filed under this section for a taxable year, (B) on such return there is a substantial understatement 7 of tax attributable to grossly erroneous items 8 of one spouse, (C) other spouse establishes that in signing the return he or she did not know, and had no reason to know, that there was such substantial understatement and ■ (D) taking into account all the facts and circumstances, it is inequitable to hold the other spouse liable for the deficiency in tax for such taxable year attributable to such substantial understatement, THEN The other spouse shall be relieved of liability for tax (including interest, penalties, and other amounts) for such taxable year to the extent such liability is attributable to such substantial understatement.”
7 later decisions quote this exact passage · from the majority“he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.”
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.