Thibodeau v. United States’s Empirical Analysis
828 F.2d 1499 · 1987
Citation profile
47 federal appellate · 6 district ·
How this case has been cited
Cited by 114 later decisions — most recently May 2019 · most notably Purcell v. United States (1993), Barnett v. Internal Revenue Service (1993)
47 federal appellate · 6 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. § 6656 · 26 U.S.C. § 6672 · 26 U.S.C. § 7501 · 28 U.S.C. § 46
Relies on Bonner v. City of Prichard · Atlantic Richfield Co. v. Newman Oil Co. · Slodov v. United States · Mazo v. United States · Howard v. United States
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 114 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the holding of corporate office, control over financial affairs, the authority to disburse corporate funds, stock ownership, and the ability to hire and fire employees.”
11 later decisions quote this exact passage · from the majority“Any person required to collect, truthfully account for, and pay over any tax imposed by this title who willfully fails to collect such tax, or truthfully account for and pay over such tax, or willfully attempts in any manner to evade or defeat any such tax or the payment thereof, shall, in addition to other penalties provided by law, be liable to a penalty equal to the total amount of the tax evaded, or not collected, or not accounted for and paid over.”
9 later decisions quote this exact passage · from the majority“`meaning, in general, a voluntary, conscious and intentional act.'”
7 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.