Akland v. Commissioner’s Empirical Analysis
1985
Citation profile
23 federal appellate ·
How this case has been cited
Cited by 93 later decisions — most recently June 2016 · most notably Bradford v. Commissioner (1986), Niedringhaus v. Commissioner (1992)
23 federal appellate ·
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. § 6653
Relies on Jackson v. Virginia · Spies v. United States · Wayte v. United States · Douglas v. Alabama · United States v. Pomponio
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 93 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“intentional wrongdoing on the part of the taxpayer with the specific intent to avoid a tax known to be owing.”
10 later decisions quote this exact passage · from the majority“left with the definite and firm conviction ... that there is no clear and convincing evidence of fraud.”
2 later decisions quote this exact passage · from the majority“The Commissioner must prove fraud by clear and convincing evidence.”
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.