Crocker v. Commissioner’s Empirical Analysis
1989
Citation profile
1 federal appellate · 1 district ·
How this case has been cited
Cited by 224 later decisions — most recently August 2020 · most notably Clayton v. Commissioner (1994), Estate of La Meres v. Comm'r (1992)
1 federal appellate · 1 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 United States v. Boyle · Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal Revenue · Commissioner of Internal Revenue v. Asphalt Products Co Inc Asphalt Products Co Inc · Electric & Neon, Inc. v. Commissioner · N.L.R.B. v. A. Brandt Company, Inc
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 224 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a bona fide and reasonable estimate of his tax liability [for each year] based on the information available to him at the time he makes his request for extension [for that year].”
4 later decisions quote this exact passage“be accompanied by the full remittance of the amount properly estimated as tax which is unpaid as of the date prescribed for the filing of the return.”
4 later decisions quote this exact passage“§ 6651(a)(1) In the case of failure— to file any return ... on the date prescribed therefor (determined with regard to any extension of time for filing), unless it is shown that such failure is due to reasonable cause and not due to willful neglect, there shall be added to the amount required to be shown as tax on such return 5 percent of the amount of such tax if the failure is for not more than 1 month, with an additional 5 percent for each additional month or fraction thereof during which such failure continues, not exceeding 25 percent in the aggregate.”
3 later decisions quote this exact passage
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.