United States v. Fox’s Empirical Analysis
721 F.2d 32 · 1983
Citation profile
17 federal appellate · 4 district · 3 state decisions
How this case has been cited
Cited by 59 later decisions — most recently September 2020 · most notably In re Grand Jury Subpoenas Duces Tecum (1983), United States v. Edgerton (1984)
17 federal appellate · 4 district · 3 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 26 U.S.C. § 7402 · 26 U.S.C. § 7602 · 26 U.S.C. § 7604
Relies on Boyd v. United States · Hoffman v. United States · Fisher v. United States · United States v. Powell · Rideout v. United States
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'if the existence and location of the subpoenaed papers are unknown to the government'”
6 later decisions quote this exact passage · from the majority“[MJerely because the IRS obtained some information from the face of Fox’s tax returns does not mean that the government now knows enough to eliminate any possibility that Fox’s production would constitute an incriminating testimonial act. For example, the IRS has no way of knowing from the face of Fox’s return whether he has records to support all of his claimed business deductions; whether he possesses records that reflect unreported taxable income; or whether he possesses records that evidence possible crimes committed in the course of his sole proprietorship. Similarly, the mere fact that a tax return reveals on its face that a taxpayer had “at least one bank account” or “brokerage account” does not give the IRS any information about whether the taxpayer has records of other bank accounts showing income that was never reported in his return.”
2 later decisions quote this exact passage · from the majority“The inference we draw from this broad-sweeping summons is that the government is attempting to compensate for its lack of knowledge by requiring [the witness] to become the primary informant against himself.”
2 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.