Badaracco v. Commissioner’s Empirical Analysis
1982
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 24 later decisions (1 by the Supreme Court) — most recently September 2014
9 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.
Appellate journey
Relationships
Applies 26 U.S.C. § 6501 · 26 U.S.C. § 7206 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Rose v. Lundy · Blue Chip Stamps v. Manor Drug Stores · Chapman v. Houston Welfare Rights Organization · Watt v. Alaska · Gilbert v. First National Bank of Jackson
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Except as otherwise provided in this section, the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed (whether or not such return was filed on or after the date prescribed) ... and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period.”
3 later decisions quote this exact passage · from the dissent“(1) False Return. In the case of a false return or fraudulent return with intent to evade tax, the tax may be assessed, or a proceeding in court for collection of such tax may be begun without assessment, at any time.”
3 later decisions quote this exact passage · from the dissent“It has long been the policy of the I.R.S. to defer civil assessment and collection until the completion of criminal proceedings.”
3 later decisions 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.