United States v. Garber’s Empirical Analysis
607 F.2d 92 · 1979
Citation profile
86 federal appellate · 5 state decisions
How this case has been cited
Cited by 108 later decisions — most recently March 2024 · most notably Goland v. Central Intelligence Agency (1978), United States v. Frazier (2004)
86 federal appellate · 5 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
Applies 26 U.S.C. § 1012 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 7201
Relies on Holland v. United States · Morissette v. United States · Helvering v. Clifford · Santoni v. United States · Commissioner of Internal Revenue v. Glenshaw Glass Company
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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] criminal proceeding pursuant to section 7201 is an inappropriate vehicle for pioneering interpretations of tax law.”
3 later decisions quote this exact passage · from the majority“a negligent, careless, or unintentional understatement of income” does not violate section 7201; rather,”
3 later decisions quote this exact passage · from the majority“By disallowing [the expert’s testimony] that a recognized theory of tax law supports Garber’s feelings, the court deprived the defendant of evidence showing her state of mind to be reasonable.”
2 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.