Otsuki v. Commissioner’s Empirical Analysis
1969
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 666 later decisions — most recently October 2019 · most notably Rowlee v. Commissioner (1983), Stone v. Commissioner (1971)
6 federal appellate ·
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. § 7201
Relies on Holland v. United States · Helvering v. Mitchell · United States v. Johnson · Fanchon & Marco, Inc. v. Paramount Pictures, Inc. · Railway Employes' Department v. Hanson
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 666 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is not material that Arctic's conviction was based upon a guilty plea, because for purposes of applying the doctrine of collateral estoppel, as well as for other purposes, there is no difference between a judgment of conviction based upon such a plea and a judgment of conviction rendered after a trial on the merits. . . . Arctic's plea of guilty to this indictment was therefore a conclusive judicial admission that its return for 1946 was false and fraudulent and that the deficiency in tax which was the necessary result of its being filed was due to fraud with intent to evade tax.”
1 later decision quote this exact passage · from the majority“In sustaining his burden of proof, respondent is not required to prove the precise amount of the underpayment resulting from fraud, but only that 'any part' of the underpayment is attributable thereto.”
1 later decision quote this exact passage“that respondent cannot meet his own burden of establishing fraud on the basis of petitioners' failure to discharge the burden of proving error in the determination of deficiencies * * *.”
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.