Druker v. Commissioner’s Empirical Analysis
1982
Citation profile
28 federal appellate · 2 district · 9 state decisions
How this case has been cited
Cited by 74 later decisions — most recently December 2018 · most notably United States v. Ven-Fuel, Inc. (1985), Lucian T. Zell, II v. Commissioner of Internal Revenue (1985)
28 federal appellate · 2 district · 9 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 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Local 408, International Brotherhood of Teamsters v. National Labor Relations Board · Zablocki v. Redhail · Bull v. United States · Castor v. United States · Schweiker v. Hansen
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The statutory language “there shall be added”, could hardly be clearer. The reasonableness of a taxpayer’s action may indeed be relevant when he is charged with negligence but not when he admittedly has flouted applicable rules and regulations which he fully understood.”
4 later decisions quote this exact passage · from the majority“'[h]arsh though the conclusion may seem', the 5 percent addition was mandatory even where the taxpayer had reasonably believed, on the advice of counsel, that a regulation issued by the Commissioner was invalid.”
1 later decision quote this exact passage · from the majority“If there is a substantial understatement of income tax for any taxable year, there shall be added to the tax an amount equal to 25 percent of the amount of any underpayment attributable to such understatement.”
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.