Erickson v. Commissioner’s Empirical Analysis
1991
Citation profile
12 federal appellate · 1 district ·
How this case has been cited
Cited by 56 later decisions (1 by the Supreme Court) — most recently April 2022 · most notably United States v. Fior D'Italia, Inc. (2002), United States v. Carey (1999)
12 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
Applies 21 U.S.C. § 952 · 26 U.S.C. § 6001 · 26 U.S.C. § 6651
Relies on Welch v. Helvering · Holland v. United States · United States v. Janis · United States v. Johnson · Tokarski 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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“some reasonable foundation for the assessment”
4 later decisions quote this exact passage · from the majority“Connecting * * * [the taxpayer] to the funds that form the basis of the deficiency is sufficient to give him the burden of proving the deficiency determination erroneous.”
2 later decisions quote this exact passage · from the majority“the presumption of correctness 'is only as strong as its rational underpinnings. Where it lacks a rational basis the presumption evaporates.' Some reasonable foundation for the assessment is necessary to preserve the presumption of correctness.”
1 later decision 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.