Fleming v. United States’s Empirical Analysis
648 F.2d 1122 · 1981
Citation profile
12 federal appellate · 1 state decisions
How this case has been cited
Cited by 41 later decisions (1 by the Supreme Court) — most recently December 2017 · most notably United States v. Boyle (1985), First National Bank of Cicero v. Lewco Securities Corp (1988)
12 federal appellate · 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. § 6075 · 26 U.S.C. § 6081 · 26 U.S.C. § 6651 · 28 U.S.C. § 1291
Relies on City of St. Louis v. Thomas W. Garland, Inc. · United States v. Grinnell Corp. · Haywood Lumber & Mining Co. v. Commissioner · Logan Lumber Co. v. Commissioner · Hatfried, Inc. 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“unable to file the return within the prescribed time.”
5 later decisions quote this exact passage“when there is no question that a return must be filed, the taxpayer has a personal, nondelegable duty to file the tax return when due.”
3 later decisions quote this exact passage · from the majority“when a taxpayer knows that a return must be filed, he has a personal, non-delegable duty to see that the return is filed on time, and the negligence or failure of his attorney to prepare and file the return does not constitute reasonable cause for a late-filing and a penalty will be imposed.”
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.