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← 692 F.2d 587 - Conforte v. Commissioner

Conforte v. Commissioner’s Empirical Analysis

1982

Citation profile

149
cited by 149 later decisions
1
cited 1 times by the Supreme Court
6
states following
May 2019
most recently cited

54 federal appellate · 3 district · 7 state decisions

How this case has been cited

Cited by 149 later decisions (1 by the Supreme Court) — most recently May 2019 · most notably Edelson v. Commissioner (1987), State Bar of Nevada v. Claiborne (1988)

54 federal appellate · 3 district · 7 state decisions

5901982199020002010decided

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. § 1348 · 26 U.S.C. § 6211 · 26 U.S.C. § 6651 · 26 U.S.C. § 6653 · 26 U.S.C. § 7203 · 26 U.S.C. § 7442 · 26 U.S.C. § 7482 · 26 U.S.C. § 911

Relies on United States v. Procter & Gamble Co. · Douglas Oil Company of California v. Petrol Stops Northwest · Helvering v. Mitchell · Railway Labor Executives' Ass'n v. Ogilvie · Molinaro v. New Jersey

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 149 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “intentional wrongdoing on the part of the taxpayer with the specific intent to avoid a tax known to be owing.”
    13 later decisions quote this exact passage · from the majority
    e.g. Lucian T. Zell, II v. Commissioner of Internal Revenue · Dodie v. Commissioner
  2. “invoke the processes of the law while [simultaneously] flouting them”
    7 later decisions quote this exact passage · from the majority
    e.g. Wood v. Pearce · Hector Clyde Wood v. Frank A. Hall
  3. “[A]s other courts have recognized, the rule should apply with greater force in civil cases where an individual's liberty is not at stake.”
    6 later decisions quote this exact passage · from the majority
    e.g. United States v. One Residential Property Located at Ocean Drive Ph-3 Juno Beach Florida · Conforte v. Commissioner of Internal Revenue

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.