United States v. Brown’s Empirical Analysis
600 F.2d 248 · 1979
Citation profile
52 federal appellate · 7 district · 7 state decisions
How this case has been cited
Cited by 84 later decisions — most recently December 2010 · most notably United States v. Wunder (1990), Jarvis v. Commissioner (1982)
52 federal appellate · 7 district · 7 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
Relies on Katz v. United States · Barker v. Wingo · Faretta v. California · Powell v. State of Alabama Patterson · Fisher 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 84 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“it is an illegal effort to stretch the Fifth Amendment to include a taxpayer who wishes to avoid filing a return,”
3 later decisions quote this exact passage · from the majority“The matter in issue is not new. The law is now established that failure to provide any information is tantamount to no return at all.”
2 later decisions quote this exact passage · from the majority“Willfulness is an essential element of the crime of failure to file an income tax return. The word ‘willfully’, used in connection with this offense, means a voluntary, intentional violation of a known legal duty, or otherwise stated, with the wrongful purpose of deliberately intending not to file a return which defendant was required by law to file and knew he should have filed. There is no necessity that the Government prove that the defendant had an intention to defraud it, or to evade the payment of any taxes, for the defendant’s failure to file to be willful under this provision of the law. Defendant’s conduct is not ‘willful’ if he acted through negligence, inadvertence, or mistake, or due to his good faith misunderstanding of the requirements of the law. It should be pointed out, how ever, that neither a defendant’s disagreement with the law, nor his own belief that such law is unconstitutional — no matter how earnestly held — constitute a defense of good faith misunderstanding or mistake. It is the duty of all citizens to obey the law whether they agree with it or not. The only purpose necessary for the Government to prove in this case is the deliberate intention on the part of the defendant not to file tax returns, which he knew he was required to file, at the time he was required by law to file them.”
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.