Smith v. United States’s Empirical Analysis
702 F.2d 741 · 1983
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 17 later decisions (1 by the Supreme Court) — most recently June 2017
10 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 26 U.S.C. § 6075 · 26 U.S.C. § 6651
Relies on Boeving v. United States · Estate of Lillehei 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The executor or executrix has a personal and nondelegable duty to file a timely return, and reliance on the mistaken advice of counsel is not sufficient to constitute 'reasonable cause' for failing to fulfill that duty”
1 later decision quote this exact passage · from the majority“unless it is shown that [the failure to file on time] is due to reasonable cause and not due to willful neglect.”
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.