Holker v. United States’s Empirical Analysis
737 F.2d 751 · 1984
Citation profile
16 federal appellate · 1 state decisions
Relationships
Applies 26 U.S.C. § 6702 · 26 U.S.C. § 6703
Relies on S.S. Zoe Colocotroni v. Puerto Rico · United States v. Moore · Funk v. Commissioner · United States v. Grabinski
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Civil penalty — If— (1) any individual files what purports to be a return of the tax imposed by subtitle A but which— (A) does not contain information on which the substantial correctness of the self-assessment may be judged, or (b) contains information that on its face indicates that the self-assessment is substantially incorrect; and (2) the conduct referred to in paragraph (1) is due to— (A) a position which is frivolous, or (B) a desire (which appears on the purported return) to delay or impede the administration of Federal income tax laws,”
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.