Penn Mutual Indemnity Co. v. Commissioner’s Empirical Analysis
277 F.2d 16 · 1960
Citation profile
17 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 49 later decisions — most recently October 2019 · most notably Roberts v. Commissioner (1974), Shomaker v. Commissioner (1962)
17 federal appellate · 1 district · 2 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 New Colonial Ice Co. v. Helvering · Brushaber v. Union Pacific Railroad · Chas Steward Mach Co v. Davis · Costello v. United States · United State v. Kahriger
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It would be unfortunate indeed if a taxpayer’s substantive rights depended upon whether he showed his claim upon the form itself or upon a document accompanying it, especially if the document is attached to his return. * * * The Tax Court, therefore, had jurisdiction to hear the taxpayer’s case.”
1 later decision quote this exact passage · from the majority“it is [not] a violation of due process to impose a tax on gross receipts regardless of the fact that expenditures exceed the receipts.... The mere fact of intake being less than outgo does not relieve the taxpayer of an otherwise lawfully imposed tax.”
1 later decision quote this exact passage · from the majority“to lay and collect taxes on incomes, from whatever source derived, without apportionment,”
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.