Bradford v. Commissioner’s Empirical Analysis
1986
Citation profile
46 federal appellate · 2 state decisions
How this case has been cited
Cited by 626 later decisions — most recently November 2023 · most notably Petzoldt v. Commissioner (1989), DiLeo v. Commissioner (1991)
46 federal appellate · 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
Applies 26 U.S.C. § 6653 · 26 U.S.C. § 6654
Relies on Spies v. United States · Goss v. Board of Education · Stone v. Commissioner · Webb v. Commissioner
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 626 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Such 'badges of fraud' ... include: (1) understatement of income; (2) inadequate records; (3) failure to file tax returns; (4) implausible or inconsistent explanations of behavior; (5) concealing assets; and (6) failure to cooperate with tax authorities.”
81 later decisions quote this exact passage · from the majority“"Arithmetic precision was originally and exclusively in [Page's] hands, and he had a statutory duty to provide it.... [H]aving defaulted in his duty, he cannot frustrate the Commissioner’s reasonable attempts by compelling investigation and recomputation under every means of income determination. Nor should he be overly chagrined at the Tax Court's reluctance to credit every word of his negative wails.””
8 later decisions quote this exact passage · from the majority“Fraud under section 6653 is 'intentional wrongdoing on the part of the taxpayer with the specific intent to avoid a tax known to be owing.' " Id. at 833. "Because fraudulent intent is rarely established by direct evidence, this court has inferred intent from various kinds of circumstantial evidence.”
6 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.