Swenson v. Thomas’s Empirical Analysis
164 F.2d 783 · 1947
Citation profile
28 federal appellate · 2 district ·
How this case has been cited
Cited by 59 later decisions — most recently November 2017 · most notably Weible v. United States (1957), Sochurek v. Commissioner (1962)
28 federal appellate · 2 district ·
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. § 116
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"[The regulation] excludes a 'mere transient or sojourner’, and correctly. A transient means literally 'one going across’, or passing through. 'Sojourner’ is built around the French word 'jour’, meaning a day, and signifies a mere temporary presence or visit.””
5 later decisions quote this exact passage · from the majority“An alien actually present in the United States who is not a mere transient or sojourner is a resident of the United States for purposes of the income tax.... One who comes to the United States for a definite purpose which in its nature may be promptly accomplished is a transient; but, if his purpose is of such a nature that an extended stay may be necessary for its accomplishment, and to that end the alien makes his home temporarily in the United States, he becomes a resident, though it may be his intention at all times to return to his domicile abroad when the purpose for which he came has been consummated or abandoned.”
4 later decisions quote this exact passage · from the majority““Viewing the entire picture of plaintiff’s life in Germany in the light of the Congressional objective, it is clear that plaintiff was a bona fide resident of a foreign country * * * within the meaning of the exemption statute. The Government’s contrary conclusion stems from placing undue emphasis upon isolated and special aspects of plaintiff’s life abroad.” (Italics ours.)-”
3 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.