Lucian T. Zell, II v. Commissioner of Internal Revenue’s Empirical Analysis
1985
Citation profile
7 federal appellate · 5 district · 2 state decisions
How this case has been cited
Cited by 88 later decisions — most recently January 2020 · most notably Kotmair v. Commissioner (1986), Alexander Shokai, Inc. v. Commissioner (1994)
7 federal appellate · 5 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
Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · Spies v. United States · Local 408, International Brotherhood of Teamsters v. National Labor Relations Board · Helvering v. Mitchell
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 88 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'actual, intentional wrongdoing, and the intent required is the specific purpose to evade a tax believed to be owing.'”
6 later decisions quote this exact passage · from the majority“an 'affirmative act' of misrepresentation sufficient to justify the fraud penalty.”
6 later decisions quote this exact passage · from the majority“concealment of assets or covering up sources of income, handling of one's affairs to avoid making the records usual in transactions of the kind, and any conduct, the likely effect of which would be to mislead or to conceal.”
3 later decisions quote this exact passage · from the concurrence
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.