S. Nicholas Jacobs and Dolores I. Jacobs v. Commissioner of Internal Revenue’s Empirical Analysis
1955
Citation profile
23 federal appellate · 2 district ·
How this case has been cited
Cited by 63 later decisions — most recently November 2010 · most notably Redwing Carriers, Inc. v. Tomlinson (1968), Pollack v. Commissioner (1966)
23 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. § 53
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · United States v. Cumberland Public Service Co. · Pacific Nat Co v. Welch
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 63 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Change from one method to the other, as petitioner seeks, would require recom-putation and readjustment of tax liability for subsequent years and impose burdensome uncertainties upon the administration of the revenue laws. It would operate to enlarge the statutory period for filing returns * * * to include the period allowed for recovering overpayments * * *. There is nothing to suggest that Congress intended to permit a taxpayer, after expiration of the time within which return is to be made, to have his tax liability computed and settled according to the other method. * * *”
4 later decisions quote this exact passage“whether for tax purposes several acts constitute separate and distinct transactions or are integrated steps in a single transaction is a question of fact”
3 later decisions quote this exact passage“binding election” rule as set forth by the Supreme Court in Pacific National Co. has been recognized consistently as controlling the general issue before us, a body of case law has arisen in which the courts have distinguished and refined the”
1 later decision quote this exact passage
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.