Gould v. Gould’s Empirical Analysis
245 U.S. 151 · 1917
Citation profile
402 federal appellate · 132 district · 343 state decisions
How this case has been cited
Cited by 1,314 later decisions (60 by the Supreme Court) — most recently March 2025 · most notably United States v. Anderson (1926), Old Colony Co v. Commissioner of Internal Revenue (1932)
402 federal appellate · 132 district · 343 state decisions — followed in 33 states
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 Audubon v. Shufeldt · American Net & Twine Co. v. Worthington · Benziger v. United States
Cited together with United States v. Merriam · Crooks v. Harrelson · Douglas v. Willcuts · Eisner v. Macomber · Smietanka v. First Trust & Savings Bank
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 1,314 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the interpretation of statutes levying taxes it is the established rule not to extend their provisions, by implication, beyond the clear import of the language used, or to enlarge their operations so as to embrace matters not specifically pointed out. In case of doubt they are construed most strongly against the government, and in favor of the citizen.”
65 later decisions quote this exact passage · from the majority““The use of 'the word itself in the definition of ‘income’ causes some obscurity, but we are unable to assert that alimony paid to a divorced wife under a decree of court falls fairly within any of the terms employed. “In Audubon v. Shufeldt, 181 U. S. 575 , 577, 578, 21 S. Ct. 735 , 736, 45 L. Ed. 1009 , we said: ‘Alimony does not arise from any business transaction, but from the relation of marriage. It is not founded on a contract, express or implied, but on the natural and legal duty of the husband to support the wife. The general obligation to support is made specific by the decree of the court of appropriate jurisdiction. * * * Permanent alimony is regarded rather as a portion of the husband’s estate to which the wife is equitably entitled, than as strictly a debt; alimony from time to time may be regarded as a’portion of his current income or earnings. * * *’ “The net income of the divorced husband subject to taxation was not decreased by payment of alimony under the court’s order; and, on the other hand, the sum received by the wife on account thereof cannot be regarded as income arising or accruing to her within the enactment.””
1 later decision quote this exact passage · from the majoritye.g. Buck v. McLaughlin““In the first place, it is, as I conceive, a general rule in the interpretation of all statutes levying taxes or duties upon subjects or citizens, not to extend their provisions, by implication, beyond the clear import of the language used, or to enlarge their operation so as to embrace matters not specifically pointed out, although standing upon a close analogy. In every case, therefore, of doubt, such statutes are construed most strongly against the government, and in favor of the subjects or citizens, because burdens are not to be imposed, nor presumed to be imposed, beyond what the statutes expressly and clearly import.””
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.