Petzoldt v. Commissioner’s Empirical Analysis
1989
Citation profile
6 federal appellate · 2 district ·
How this case has been cited
Cited by 669 later decisions — most recently October 2020 · most notably HIGBEE v. COMMISSIONER OF INTERNAL REVENUE (2001), Niedringhaus v. Commissioner (1992)
6 federal appellate · 2 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
Relies on Matsushita Electric Industrial Co., Ltd. v. Zenith Radio Corporation · Miranda v. State of Arizona Vignera · Welch v. Helvering · Holland v. United States · Ohio Bureau of Employment Services v. Hodory
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 669 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“need only be reasonable in light of all surrounding facts and circumstances.”
24 later decisions quote this exact passage · from the majoritye.g. Ekwenugo v. Comm'r · Rey v. Comm'r“is persuasive circumstantial evidence of fraud.”
7 later decisions quote this exact passage · from the majority“The absence of statutory guidelines suggests that Congress intended that respondent should have great latitude in making determinations of liability, particularly where the taxpayer files no returns and refuses to cooperate in the ascertainment of his income. Thus, respondent is entitled to use any reasonable means of reconstructing income. Further, he is given greater latitude in determining which method of reconstruction to apply where the case involves an illegal enterprise in which the taxpayer has failed to file a return and has kept no records. Nor is mathematical exactitude required of respondent, for if it were it “would be tantamount to holding that skillful concealment is an invincible barrier to proof.””
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.