Maguire v. Trefry’s Empirical Analysis
253 U.S. 12 · 1920
Citation profile
8 federal appellate · 2 district · 93 state decisions
How this case has been cited
Cited by 160 later decisions (43 by the Supreme Court) — most recently June 2019 · most notably Irwin v. Gavit (1925), Miller Bros. v. Maryland (1954)
8 federal appellate · 2 district · 93 state decisions — followed in 24 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.
Appellate journey
reviewedMaguire v. Tax Commissioner
Relationships
Relies on Union Refrigerator Transit Company v. Commonwealth of Kentucky · Blackstone v. Miller · DeGanay v. Lederer · Kirtland v. Hotchkiss
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 160 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"* * * Domicile or residence within the state is a valid basis for the imposition of an income tax by the state. It is competent for a state to impose a tax on the income of a resident thereof, or a domestic corporation, whether such income be derived from sources within or outside the state. The enjoyment of the privileges of residence within the state and the attendant right to invoke the protection of its laws are inseparable from responsibility for sharing the costs of government, and a tax measured by the net income of residents is an equitable method of distributing the burden of government among those privileged to enjoy its benefits. The tax is founded on the protection afforded by the state to the recipient of the income in his person, in his right to receive the income, and in his enjoyment of it when received; these are rights and privileges which attach to domicile within the state and the economic advantage realized by the receipt of income and the power to control it bear a direct relationship to the rights and privileges attached to domicile and to the equitable distribution of the tax burden. Neither the privilege nor the burden is affected by the character of the -source from which the income is derived % * # 1 W”
2 later decisions quote this exact passage · from the majority““It is true that the legal title of the property is held by the trustee in Pennsylvania. But it is so held for the benefit of the beneficiary of the trust, and such beneficiary has an equitable right, title and interest distinct from its legal ownership. ‘ The legal owner holds the direct and absolute dominion over the property in the view of the law;.but the income, profits, or benefits thereof in his hands, belong wholly, or in part, to others.’ ””
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.