Goodenow v. Commissioner’s Empirical Analysis
1956
Citation profile
17 federal appellate ·
How this case has been cited
Cited by 30 later decisions (3 by the Supreme Court) — most recently April 2012 · most notably Colony, Inc. v. Commissioner (1958), Homan v. United States (1960)
17 federal appellate ·
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. § 275
Relies on Birmingham v. Geer · United States v. Jeffers · Deakman-Wells Co. v. Commissioner of Internal Revenue · Uptegrove Lumber Co. v. Commissioner · Slaff 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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Limitations on assessment and collection. “(a) General rule “Except as otherwise provided in this section, the amount of any tax imposed by this title shall be assessed within 3 years after the return was filed (whether or not such return was filed on or after the date prescribed) or, if the tax is payable by stamp, at any time after such tax became due and before the expiration of 3 years after the date on which any part of such tax was paid, and no proceeding in court without assessment for the collection of such tax shall be begun after the expiration of such period. . . . [[Image here]] “(e) Substantial omission of items “Except as otherwise provided in subsection (c)— “(1) Income taxes “In the case of any tax imposed by subtitle A— “(A) General rule “If the taxpayer omits from gross income an amount properly includible therein which is in excess of 25 percent of the amount of gross income stated in the return, the tax may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time within 6 years after the return was filed. For purposes of this subparagraph— “(i) In the case of a trade or business, the term ‘gross income’ means the total of the amounts received or accrued from the sale of goods or services (if such amounts are required to be shown on the return) prior to diminution by the cost of such sales or services; and “(ii) In determining the amount omitted from gross income, there shall not be taken into accoun”
2 later decisions quote this exact passage · from the majority“Respect for the decisions of other circuits is especially important in tax cases because of the importance of uniformity, and the decision of the Court of Appeals of another circuit should be followed unless it is shown to be incorrect.”
1 later decision quote this exact passage · from the majority“assessed within 3 years after the return was filed * * *.”
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.