Tooley v. Commissioner’s Empirical Analysis
121 F.2d 350 · 1941
Citation profile
13 federal appellate · 5 state decisions
How this case has been cited
Cited by 28 later decisions (1 by the Supreme Court) — most recently June 1992 · most notably Commissioner v. Stern (1958), Mysse v. Commissioner (1972)
13 federal appellate · 5 state decisions
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 Erie Co v. Tompkins · Helvering v. Clifford · Burnet v. Harmel · Phillips v. Commissioner · Helvering v. Hallock
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Fidtjciaky oir Taxpayer. — Upon notice to the Commissioner that any person is acting in a fiduciary capacity such fiduciary shall assume the powers, rights, duties, and privileges of the taxpayer in respect of a tax imposed by this chapter (except as otherwise specifically provided and except that the tax shall be collected from the estate of the taxpayer), until notice is given that the fiduciary capacity has terminated.”
1 later decision quote this exact passage · from the majority“The “notice to the Commissioner” provided for in section 312 shall be a written notice signed by the fiduciary and filed with the Commissioner. The notice must state the name and address of the person for whom the fiduciary is acting, and the nature of the liability of such person; that is, whether it is a liability for tax, and, if so, the year or years involved, * * * [Sec. 29.312-1, Begs. 111.]”
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.