Dellacroce v. Commissioner’s Empirical Analysis
1984
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 128 later decisions — most recently February 2018 · most notably Tokarski v. Commissioner (1986), Petzoldt v. Commissioner (1989)
10 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
Relies on Welch v. Helvering · Hoffman v. United States · Baxter v. Palmigiano · Helvering v. Taylor · United States v. Janis
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 128 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“evidence used or the propriety of the commissioner's motives or administrative policy or procedure in making the determination.... '[T]he Commissioner's determination may often rest upon hearsay or other inadmissible evidence, and we know of no rule of law calling for a review of the materials that were before the Commissioner in order to ascertain whether he relied upon improper evidence.'”
5 later decisions quote this exact passage · from the concurrence“The evidence of record must at least link the taxpayer with some tax-generating acts, such as the purchase or sale of controlled substances.”
1 later decision quote this exact passage · from the concurrence“'naked' assessment without any foundation whatsoever.”
1 later decision 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.