Considine v. Commissioner’s Empirical Analysis
1977
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 36 later decisions — most recently April 1993 · most notably Considine v. United States (1982), Lollis v. Commissioner (1979)
3 federal appellate ·
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 18 U.S.C. § 641 (Livestock Fraud Protection Act)
Relies on Commissioner v. Sunnen · Spies v. United States · United States v. Murdock · United States v. Pomponio · United States v. Bishop
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(b) Fraud. — If any part of any underpayment (as defined in subsection (c)) of tax required to be shown on a return is due to fraud, there shall be added to the tax an amount equal to 50 percent of the underpayment. In the case of income taxes and gift taxes, this amount shall be in lieu of any amount determined under subsection (a).”
2 later decisions quote this exact passage“a conviction under section 7206(1) for willfully making a return which the taxpayer does not believe to be true and correct is proof that the return is fraudulent.”
1 later decision quote this exact passage“necessary element of proof under sec. 6653(b).”
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.