Carson v. United States’s Empirical Analysis
560 F.2d 693 · 1977
Citation profile
66 federal appellate ·
How this case has been cited
Cited by 143 later decisions — most recently November 2023 · most notably Weimerskirch v. Commissioner (1979), Portillo v. Commissioner (1991)
66 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. § 4401 · 26 U.S.C. § 4411 · 26 U.S.C. § 7421
Relies on United States v. Janis · Bull v. United States · Frey v. United States · Webb v. Commissioner · Pizzarello 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 143 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The tax collector's presumption of correctness has a herculean muscularity of Goliathlike reach, but we strike an Achilles' heel when we find no muscles, no tendons, no ligaments of fact.”
15 later decisions quote this exact passage · from the majority““Such a position, which would support the most arbitrary of assessments so long as the taxpayer found himself unable to prove a negative, frequently difficult in quite innocent circumstances, does not become the government’s agents, and we readily reject it.””
4 later decisions quote this exact passage · from the majority“[T]he absence of adequate tax records does not give the Commissioner carte blanche for imposing Draconian absolutes ... [even though] such absence does weaken any critique of the Commissioner's methodology.”
4 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.