Miller v. Commissioner’s Empirical Analysis
144 F.2d 287 · 1944
Citation profile
19 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 55 later decisions — most recently January 2009 · most notably Feistman v. Commissioner (1974), Sibla v. Commissioner (1977)
19 federal appellate · 1 district · 4 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
Applies 26 U.S.C. § 22
Relies on Helvering v. Winmill · Burnet v. Wells · Grady v. Garland · Brodie v. Commissioner · Commissioner of Internal Revenue v. Bonwit
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““These aspects of the retirement plan seem to us to demonstrate that there have been purchased by the employee substantial rights * *. They are * * * comparable to, and for our purposes indistinguishable from, an annuity contract, of which the employer constitutes itself the issuer, setting aside reserves for that purpose and making investments thereof comparable to those which would be employed by companies engaged in that business.” 3”
6 later decisions quote this exact passage · from the majority“These rights were secured in consideration of contributions made from his salary, and at least to the extent of such contributions made, they could not be taken from him under the provisions of the Act, and we may not assume that Congress, if it could, would change the law so as to deprive him of substantial rights acquired thereunder.”
6 later decisions 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.