Cloud v. Commissioner’s Empirical Analysis
1991
Citation profile
How this case has been cited
Cited by 34 later decisions — most recently October 2020 · most notably Shelton v. Commissioner (1995), Geary v. Commissioner (1999)
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 · Commissioner of Internal Revenue v. Heininger · Neely v. Commissioner · Bixby v. Commissioner · Commissioner of Internal Revenue v. F Tellier
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(c) Authority to Waive. -- The Secretary may waive all or any part of the addition to tax provided by this section on a showing by the taxpayer that there was reasonable cause for the understatement (or part thereof) and that the taxpayer acted in good faith.”
1 later decision quote this exact passage“in connection with any attempt to influence the general public, or segments, thereof, with respect to legislative matters, elections, or referendums.”
1 later decision 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.