Commissioner of Internal Revenue V. Miller’s Empirical Analysis
226 F.2d 618 · 1955
Citation profile
15 federal appellate · 2 district ·
How this case has been cited
Cited by 38 later decisions — most recently July 1993 · most notably United States v. Johnson (1964), Martin v. Commissioner (1956)
15 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. § 165
Relies on Miller v. Commissioner
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Both this Court and the Internal Revenue Service have recognized the plight of employee-participants in retirement plans that have been terminated due to a bona fide change in the ownership of the business and have found a ‘separation from the service’ within the meaning of this Code provision even though the employees in fact continued in their same jobs with the new owners.””
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.