Borgeson v. United States’s Empirical Analysis
757 F.2d 1071 · 1985
Citation profile
23 federal appellate · 2 district ·
How this case has been cited
Cited by 36 later decisions — most recently November 2010 · most notably United States v. Rowlee (1990), United States v. Dawes (1989)
23 federal appellate · 2 district ·
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. § 6065 · 26 U.S.C. § 6702 · 26 U.S.C. § 7422 · 28 U.S.C. § 1331
Relies on Wisconsin v. Yoder · Arnett v. Kennedy · Alexander v. "Americans United" Inc. · Zellerbach Paper Co. v. Helvering · Lucas v. Pilliod Lumber Co.
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A person shall pay a penalty of $5,000 if— (1) Such person files what purports to be a return of a tax imposed by this title but which— (A) does not contain information on which the substantial correctness of the self-assessment may be judged, [and] (2) the conduct referred to in paragraph (a)— (A) is based on a position which the Secretary has identified as frivolous under subsection (c), or (B) reflects a desire to delay or impede the administration of Federal tax laws.”
2 later decisions quote this exact passage · from the majority“Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.”
1 later decision quote this exact passage · from the majority“any return, declaration, statement, or other document required to be made under any provision of the internal revenue laws or regulations shall contain or be verified by a written declaration that it is made under penalties of perjury.”
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.