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← 62 TC 834 - Roberts v. Commissioner

Roberts v. Commissioner’s Empirical Analysis

1974

Citation profile

366
cited by 366 later decisions
March 2023
most recently cited

8 federal appellate ·

How this case has been cited

Cited by 366 later decisions — most recently March 2023 · most notably Cupp v. Commissioner (1975), Estate of Mason v. Commissioner (1975)

8 federal appellate ·

1360197419801990200020102020decided

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. § 51 · 28 U.S.C. § 1652 (Rules of Decision Act)

Relies on Erie Co v. Tompkins · Welch v. Helvering · New Colonial Ice Co. v. Helvering · Deputy v. du Pont · Sorrells 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 366 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[t]he privilege against self-incrimination does not apply where the possibility of criminal prosecution is remote or unlikely.”
    2 later decisions quote this exact passage
  2. “If the petitioner's constitutional rights would not be violated through the enforcement of a summons for his tax records, clearly there is no constitutional violation by placing the burden of proof on him.”
    1 later decision quote this exact passage
  3. “State law may control only when the federal taxing act, by express language or necessary implication, makes its own operation dependent upon state law.”
    1 later decision 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.