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← 55 TC 85 - Beaver v. Commissioner

Beaver v. Commissioner’s Empirical Analysis

1970

Citation profile

760
cited by 760 later decisions
September 2019
most recently cited

6 federal appellate ·

How this case has been cited

Cited by 760 later decisions — most recently September 2019 · most notably Rowlee v. Commissioner (1983), Gajewski v. Commissioner (1976)

6 federal appellate ·

357019701980199020002010decided

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. § 6653 · 26 U.S.C. § 7454

Relies on Stoltzfus v. United States · Powell v. Granquist · Stratton v. Commissioner · Acker v. Commissioner · Carter v. Campbell

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

  1. “[A] willful attempt to evade tax may be found from any conduct calculated to mislead or conceal.”
    3 later decisions quote this exact passage
  2. “Fraud is never presumed. It must be affirmatively established by clear and convincing evidence.”
    2 later decisions quote this exact passage
  3. “(c) Definition of Underpayment. — For purposes of this section, the term "underpayment” means— (1) Income, estate, gift, and certain excise taxes.— In the case of a tax to which section 6211 (relating to income, estate, gift, and certain excise taxes) is applicable, a deficiency as defined in that section (except that, for this purpose, the tax shown on a return referred to in section 6211(aXlXA) shall be taken into account only if such return was filed on or before the last day prescribed for the filing of such return, determined with regard to any extension of time for such filing) * * *”
    1 later decision quote this exact passage

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.