Stoddard v. Commissioner’s Empirical Analysis
141 F.2d 76 · 1944
Citation profile
23 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 42 later decisions (2 by the Supreme Court) — most recently September 1987 · most notably Commissioner v. Sunnen (1948), Fairmont Aluminum Co. v. Commissioner (1954)
23 federal appellate · 1 district · 2 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 Higgins v. Commissioner · Helvering v. Southwest Consolidated Corp. · Helvering v. Cement Investors, Inc. · McClain v. Commissioner · Campana Corp. v. Harrison
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Each taxable year is a separate taxable period; different taxes are involved, and the events of each period are given their significance in tax matters in the light of what actually took place in that taxable year. Whether one is doing business or not within § 23 [the predecessor to 26 U.S.C. § 165 ] is often a most difficult question to decide and often depends upon the aggregate of many considerations, in themselves perhaps of minor consequence but decisive when taken as a whole. A taxpayer must of necessity prove his actual status in the period in which he seeks an advantage that being in business would give him. It is not a subject which when settled as to one period remains immutable as to another.”
1 later decision quote this exact passage · from the majority““The point as to res adjudicata falls when considered in the light of the statutory scheme of income taxation. Each taxable year is a separate taxable period; different taxes are involved, and the events of each period are given their significance in tax matters in the light of what actually took place in that taxable year.””
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.