United States v. Clements’s Empirical Analysis
73 F.3d 1330 · 1996
Citation profile
70 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 111 later decisions — most recently June 2025 · most notably United States v. Posada-Rios (1998), United States v. Mann (1998)
70 federal appellate · 1 district · 2 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 18 U.S.C. § 1001 (Comprehensive Thrift and Bank Fraud Prosecution and Taxpayer Recovery Act of 1990) · 18 U.S.C. § 3553 · 26 U.S.C. § 7201
Relies on United States v. Olano · Williams v. United States · National Union Fire Insurance v. Helfand · Michel v. United States · Nicholas 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 111 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as used in 2T1.4(b)(2), includes conduct that is more complex or demon strates greater intricacy or planning than a routine tax-evasion case. An enhancement would be applied, for example, where the defendant used offshore bank accounts or transactions through corporate shells or fictitious entities. 22 USSG 2T1.4, cmt. n.3. The district court applied the enhancement”
2 later decisions quote this exact passage · from the majority“Even though [the defendant's] transactions did not involve the use of offshore bank accounts or fictional entities, his use of multiple cashier's checks and his wife's separate bank account to obscure the [offense] undeniably made it more difficult for the IRS to detect his evasion,”
2 later decisions quote this exact passage · from the majority“[t]he cross references in these sections and the accompanying comments plainly indicate that the amount of the `tax loss' is to be calculated in a similar manner in each provision, and that the amount the parties attempted to illegally obtain from the government controls over their eventual failure to actually acquire and retain their illegal refunds.”
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.