United States v. White’s Empirical Analysis

Citation profile

13 federal appellate · 6 district · 2 state decisions

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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(1) Organizing, promoting, marketing or selling, or assisting in organizing, promoting, marketing or selling, any plan or arrangement which advises or encourages taxpayers to attempt to violate internal revenue laws or unlawfully evade the assessment or collection of their federal tax liabilities, including those that promote, sell, or advocate the use of the “zero income” tax return, and the use of false withholding forms; (2) Engaging in conduct subject to penalty under 26 U.S.C. § 6700 , including organizing or selling a plan or arrangement and making or furnishing a statement regarding the ex-cludability of income that they know or have reason to know is false or fraudulent as to any material matter; (3) Engaging in conduct subject to penalty under 26 U.S.C. § 6701 , including preparing an/or assisting in the preparation of a document related to a matter material to the internal revenue laws that they know (or have reason to believe) will result in an understatement of tax liability; (4) Advertising, marketing, or promoting any false, misleading or deceptive tax position in any media for the purpose of advising or encouraging taxpayers to unlawfully evade the assessment or payment of federal income taxes, including the positions that (1) persons can legally stop paying taxes or become tax free by using the plan or arrangement; (2) federal income tax is voluntary; (3) there is no law requiring anyone to pay income tax; (4) there is no income tax, only a profits tax; (5) it”

   5 later decisions quote this exact passage · from the majority
   e.g. United States v. Kaun · 269 F. Supp. 2d 1262 - United States v. Schiff

2. “(b)(1) that the tax preparer has— (A) engaged in any conduct subject to penalty under section 6694 or 6695 or subject to any criminal penalty provided by this title; (B) misrepresented his eligibility to practice before the Internal Revenue service, or otherwise misrepresented his experience or education as a tax return preparer; (C) guaranteed the payment of any tax refund or the allowance of any tax credit; or (D) engaged in any other fraudulent or deceptive conduct which substantially interferes with the proper administration of the Internal Revenue Laws.”

   2 later decisions quote this exact passage · from the majority
   e.g. 953 F. Supp. 2d 944 - United States v. Musin · United States v. Nordbrock

3. “The defendant, Dennis Kaun, individually and doing business as the Wisconsin Society for Educated Citizens, his agents, servants, employees, attorneys, and all those in active concert or participation with them, are hereby ENJOINED, directly and indirectly from engaging or undertaking to engage in any and all of the following activities: 1. Organizing, selling, or assisting in the organization of an entity or otherwise promoting any plan or arrangement based upon (a) the false representation that wages, salaries, or other compensation for labor or services are exempt from federal income taxation, or (b) any other such frivolous claim with respect to the scope of federal income taxation, or (c) any false or fraudulent claim regarding the allowability of any deduction or credit, the excludability of any income, or the securing of any other tax benefit for federal income tax purposes; 2. Advertising, marketing, or selling any documents or other information advising taxpayers that wages, salaries, or other income not specifically excluded from taxation under Title 26 of the United States Code are not taxable income; 3. Providing forms for or assisting any individual in the preparation of false Internal Revenue Forms W-4, W4E, 1040X, and any other form, return, or declaration claiming that the taxpayer is exempt from federal income taxation or entitled to excessive withholding allowances; 4. Filing, providing forms for, or otherwise aiding and abetting the filing of Freedom of Inf”

   1 later decision quote this exact passage · from the majority
   e.g. United States v. Kaun