Dowell v. Commissioner’s Empirical Analysis
1980
Citation profile
20 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 43 later decisions (1 by the Supreme Court) — most recently January 2008 · most notably Badaracco v. Commissioner (1984), Espinoza v. Commissioner (1982)
20 federal appellate · 2 district · 1 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. § 276
Relies on Zellerbach Paper Co. v. Helvering · Colony, Inc. v. Commissioner · Kalb v. United States · Bennett v. Commissioner
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[T]he amount of any tax imposed by this title shall be assessed within 3 years after the return was filed ... and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period.””
4 later decisions quote this exact passage“[p]erfect accuracy or completeness is not necessary to rescue a return from nullity, if it purports to be a return, is sworn to as such..., and evinces an honest and genuine endeavor to satisfy the law.”
2 later decisions quote this exact passage“once [a] taxpayer has evinced an honest and genuine effort to satisfy the law by filing such a return, the § 6501(a) period begins to run.”
2 later decisions 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.