Old Colony Trust Co. v. Commissioner’s Empirical Analysis
279 U.S. 716 · 1929
Citation profile
725 federal appellate · 96 district · 83 state decisions
How this case has been cited
Cited by 1,790 later decisions (129 by the Supreme Court) — most recently March 2025 · most notably Aetna Life Ins Co of Hartford Conn v. Haworth (1937), Commissioner of Internal Revenue v. Duberstein D Stanton (1960)
725 federal appellate · 96 district · 83 state decisions — followed in 22 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
reviewedWest End St. Ry. Co. v. Malley (from First Circuit Court of Appeals)
Relationships
Relies on Kline v. Burke Construction Co. · Osborn v. President Directors and Company of the Bank of the United States · David Muskrat v. · United States v. Sullivan
Cited together with Bogardus v. Commissioner · United States v. Boston & Maine Railroad · Douglas v. Willcuts · Commissioner v. LoBue · Helvering v. Horst
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 1,790 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The discharge by a third person of an obligation to him is equivalent to receipt by the person taxed.”
20 later decisions quote this exact passage · from the majority““The Circuit Court of Appeals is a constitutional court under the definition of such courts as given in the Bakelite case, supra, and a case or controversy may come before it, provided it involves neither advisory nor executive action by it.” (Emphasis supplied.)”
4 later decisions quote this exact passage · from the majority““The Board of Tax Appeals, established by section 900 of the Revenue Act of 1924, tit. IX, c. 234, 43 Stat. 253 , 336 [26 U.S.C.A. Int.Rev.Acts], was created by Congress to provide taxpayers an opportunity to secure an independent review of the Commissioner of Internal Revenue’s determination of additional income and estate taxes by the Board in advance of their paying the tax found by the Commissioner to be due. Before the act of 1924 the taxpayer could only contest the Commissioner’s determination of the amount of the tax after its payment.””
3 later decisions 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.