Commissioner v. Mnookin's Estate’s Empirical Analysis
184 F.2d 89 · 1950
Citation profile
63 federal appellate · 1 district ·
How this case has been cited
Cited by 98 later decisions — most recently June 2016 · most notably Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Caldwell (1953), Iley v. Commissioner (1952)
63 federal appellate · 1 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
Relies on Security Flour Mills Co. v. Commissioner · Ross v. Commissioner · Henderson's Estate v. Commissioner of Internal Revenue · Marcus Breier Sons, Inc. v. Marvlo Fabrics, Inc.
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 98 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The net income shall be computed upon the basis of the taxpayer’s annual accounting period (fiscal year or' calendar year, as the case may be) in accordanee with the method of accounting regularly employed in keeping the books of such taxpayer; but if no such method of accounting has been so employed, or if the method employed does not clearly reflect the income, the computation shall be made in accordance with such method as in the opinion of the Commissioner does clearly reflect the income. * * * ”'”
6 later decisions quote this exact passage · from the majority““The discretion which the Commissioner has under section 41 of the Code to make such computations as will clearly reflect income does not empower him to add to the taxpayer’s gross income for a given year an item which rightfully belongs to an earlier year. The mistaken omission from income of an amount properly includible does not nullify the statute of 'limitations on assessment and collection of income taxes.””
2 later decisions quote this exact passage · from the majority“The amount of all items of gross income in respect of a decedent which are not properly includible in respect of the taxable period in which falls the date of his death or a prior period shall be included in the gross income, for the taxable year when received, of: (A) the estate of the decedent, if the right to receive the amount is acquired by the decedent's estate from the decedent; * *.”
2 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.