Licari v. Commissioner’s Empirical Analysis

Citation profile

16 federal appellate · 4 state decisions

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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The remedial character of sanctions imposing additions to a tax has been made clear by this Court in passing upon similar legislation. They are provided primarily as a safeguard of the protection of the revenue and to reimburse the government for the heavy expense of investigation and the loss resulting from the Taxpayer’s fraud.”

   2 later decisions quote this exact passage · from the majority
   e.g. Little v. Commissioner · William D. Little v. Commissioner of Internal Revenue

2. “[h]ere, we are not presented with a case in which an individual acted in accordance with the law as it stood at the time only later to be subjected to a penalty; instead, those subjected to the increased penalties, like the Licaris, knew at the time that they filed their returns that they were not acting in accordance with the law and could be subjected to a fine.... Under these circumstances, we do not find imposition of the increased penalty unduly “harsh and oppressive.””

   1 later decision quote this exact passage · from the majority
   e.g. Carlton v. United States

3. “If there is a substantial understatement of income tax for any taxable year, there shall be added to the tax an amount equal to 25 percent of the amount of any underpayment attributable to such understatement.”

   1 later decision quote this exact passage · from the majority
   e.g. Little v. Commissioner