Reis v. Commissioner’s Empirical Analysis
142 F.2d 900 · 1944
Citation profile
19 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 90 later decisions (3 by the Supreme Court) — most recently July 2016 · most notably Colony, Inc. v. Commissioner (1958), Stratton v. Commissioner (1970)
19 federal appellate · 1 district · 1 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 Burnet v. Sanford & Brooks Co. · Reynolds v. Cooper · Brown v. Helvering · Woolford Realty Co. v. Rose · Detroit Edison Co. 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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a)’ General Rule. — The amount of Income taxes Imposed by this chapter shall be assessed within three years after the return was filed, and no proceeding in court without assessment for the collection of such taxes shall be begun after the expiration of such period. *»«**(** (c) Omission peom Geoss Income. — If the taxpayer omits from gross Income an amount properly includible therein which is In excess of 25 per centum of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 5 years after the return was filed.”
5 later decisions quote this exact passage · from the majority“the amount of gross income stated in the return”
2 later decisions quote this exact passage · from the majority“[W]e think the statutory provision that the “basis of property shall be the cost of such property” . . . normally means, and that in this case the Commissioner was justified in applying it to mean, cost to the taxpayer. A property may have a cost history quite different from its cost to the taxpayer. It may have been purchased for less or more than original cost, or built by contract which called for payments on which the builder profited greatly or suffered heavy loss. But generally and in this case the Commissioner was in no error in ruling that the taxpayer’s outlay is the measure of his [or her] recoupment through depreciation accruals.”
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.