Commissioner v. Oates’s Empirical Analysis
1953
Citation profile
20 federal appellate · 1 state decisions
How this case has been cited
Cited by 51 later decisions — most recently April 2003 · most notably Albertson's, Inc. v. Commissioner (1990), Basila v. Commissioner (1961)
20 federal appellate · 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
Applies 26 U.S.C. § 22
Relies on Helvering v. Horst · Lucas v. Earl · Helvering v. Eubank · Oklahoma v. Texas · Massachusetts Mut Life Ins Co v. United States
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““This case is far removed from such decisions. Here the parties were confronted by a situation where inconvenience and resulting dissatisfaction came to the retired agents by reason of the constantly decreasing payments made by the company under the original contract. To relieve the situation, the company and the taxpayer, after full and complete negotiations, before retirement of the agent, agreed to abrogate and annul the old contract, to substitute a new one and thus to improve the unsatisfactory posture of affairs. The taxpayer did not reduce to his immediate possession or to his present enjoyment anything that might thereafter accrue to him. He made no assignment; he took no dominion over the accrued commissions other than to agree to receive them in cash installments as they matured under the contract. He did nothing to charge himself with the economic benefit to be derived from the accruing commissions but, on the contrary, let them, accumulate under an agreement whereby the company was to pay the same amount every month rather than constantly decreasing amounts.” (Emphasis supplied.)”
1 later decision quote this exact passage · from the majority““* * * Thus in L’Esperance, 2 T.C.M. 442 (1943) that court said: ■* * * A new contract was entered into by the parties by which the petitioner gave up all Ms rights under the contract by which he was engaged and In return therefor was to receive and did receive $500 per month beginning March 1, 1937. * * * It cannot be doubted that renewal commissions which might have been received by the petitioner under his contract after he had resigned as branch manager would constitute taxable income of the petitioner. * * * The same rule must be followed where an amount was paid by the Assurance Co, each month in lieu of commissions upon renewal policies.’ ””
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.