United States v. Magnolia Petroleum Co.’s Empirical Analysis
276 U.S. 160 · 1928
Citation profile
84 federal appellate · 43 district · 36 state decisions
How this case has been cited
Cited by 294 later decisions (29 by the Supreme Court) — most recently March 2022 · most notably Landgraf v. USI Film Products (1994), Bowen v. Georgetown University Hospital (1988)
84 federal appellate · 43 district · 36 state decisions — followed in 12 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 Shwab v. Doyle · White v. United States · United States v. Heth · Girard Trust Co. v. United States
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 294 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[s]tatutes are not to be given retroactive effect or construed to change the status of claims fixed in accordance with earlier provisions unless the legislative purpose so to do plainly appears.”
7 later decisions quote this exact passage · from the majority““See. 1324. (a) That upon the allowance of a claim for the refund of or credit for internal revenue taxes paid, interest shall be allowed and paid upon the total amount of such refund or credit at the rate of one-half of 1 per centum per month to the date of such allowance, as follows: (1) If such amount was paid under a specific protest setting forth in detail the basis of and reasons for such protest, from the time when such tax was paid, or (2) if such amount was not paid under protest but pursuant to an additional assessment, from the time such additional assessment was paid, or (3) if no protest was made and the tax was not paid pursuant to an additional assessment, from six months after the date of filing of such claim for refund or credit. The term 'additional assessment’ as used in this section means a further assessment for a tax of the same character previously paid in part. “(b) Section 177 of the Judicial Code is amended to read as follows: 'See. 177. No interest shall be allowed on any claim up to the time of the rendition of judgment by the Court of Claims, unless upon a contract expressly stipulating for the payment of interest, except that interest may loe allowed in any judgment of any court rendered after the passage of the Revenue Act of 1921 against the United States for any internal-revenue tax erroneously or illegally assessed or collected, or for any penalty collected without authority or any sum which was excessive or in any manner wrongfully collected”
1 later decision quote this exact passage · from the majority““ Upon the allowance of a credit or refund of any internal-revenue tax erroneously or illegally assessed or collected, * * * interest shall be allowed and paid on the amount of such credit or refund * * * from the date such tax * * * was paid to the date of the. allowance of the refund * *”
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.