Brennan v. Commissioner’s Empirical Analysis
1984
Citation profile
8 federal appellate ·
Relationships
Applies 26 U.S.C. § 6702 · 26 U.S.C. § 7422 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Bell v. Wolfish · Flint v. Stone Tracy Co. · United States v. Sullivan · Garner v. United States · Walter 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Civil Penalty. — If— (1) any individual files what purports to be a return of the tax imposed by subtitle A but which— (A) does not contain information on which the substantial correctness of the self-assessment may be judged, or (B) contains information that on its face indicates that the self-assessment is substantially incorrect; and (2) the conduct referred to in paragraph (1) is due to— (A) a position which is frivolous, or (B) a desire (which appears on the purported return) to delay or impede the administration of Federal income tax laws”
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.