Cook v. Tait’s Empirical Analysis
265 U.S. 47 · 1924
Citation profile
83 federal appellate · 10 district · 3 state decisions
How this case has been cited
Cited by 240 later decisions (29 by the Supreme Court) — most recently June 2025 · most notably Flora v. United States (1960), Blackmer v. United States (1932)
83 federal appellate · 10 district · 3 state decisions
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 M'Culloch v. State of Maryland · Eisner v. Macomber · Flint v. Stone Tracy Co. · Brushaber v. Union Pacific Railroad · Knowlton v. Moore
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 240 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(c) Abandonment of U.S. citizenship or residence. Income from sources without the United States which is not effectively connected with the conduct by the tax - payer of a trade or business in the United States is not taxable if received by an alien individual while he is not a resident of the United States, even though he earns the income earlier in the taxable year while he is a citizen or resident of the United States. However, income from sources without the United States which is not effectively connected with the conduct by the taxpayer of a trade or business in the United States is taxable if received by an individual while he is a citizen or resident of the United States, even though he abandons his U.S. citizenship or residence after its receipt and before the close of the taxable year.”
2 later decisions quote this exact passage · from the majority“embraces all the attributes which appertain. to sovereignty in the fullest sense. . . . Because the limitations of the. Constitution are barriers bordering the States and preventing them from transcending the limits of their authority and thus destroying the rights of other States and at the same time saving their rights from destruction by the other States, in other words of maintaining and preserving the rights of all the States, affords no ground for constructing an imaginary constitutional barrier around the exterior confines of the United States for the purpose of shutting that government off from thé exertion of powers which inherently belong to it by virtue of its sovereignty.”
1 later decision quote this exact passage · from the majoritye.g. Burnet v. Brooks
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.