Florsheim Bros. Drygoods Co. v. United States’s Empirical Analysis
280 U.S. 453 · 1930
Citation profile
218 federal appellate · 32 district · 18 state decisions
How this case has been cited
Cited by 526 later decisions (24 by the Supreme Court) — most recently June 2021 · most notably Badaracco v. Commissioner (1984), Stearns Co of Boston Mass v. United States (1934)
218 federal appellate · 32 district · 18 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.
Appellate journey
reviewedHoward v. Commissioner (from Fifth Circuit Court of Appeals)
Relationships
Relies on Russell v. United States · Mabel Elevator Co. v. Commissioner · National Refining Co. v. Commissioner · Greylock Mills v. Commissioner
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 526 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The waivers executed by the parties were not contracts binding the Commissioner not to make the assessments and collections after the periods specified. * * * The instruments were nothing more than what they were termed on their face — waivers; and that was all to which the Commissioner was authorized to consent. “Stress is laid on the use of the words ‘agree’ and ‘agreement’ in the acts and regulations. But these are ordinary words having no technical significance. It is also urged that, unless a contract was intended, there is no reason why the consent of the Commissioner should have been required. But an otherwise plain meaning should not be distorted merely for the sake of finding a purpose for this administrative requirement. If a reason must be found, it exists in the general desirability of the requirement as an administrative matter. It serves to keep the Commissioner in closer touch with the matters which he is charged to administer. It avoids claims of improvident execution of waivers and unauthorized exactions by subordinates of the Department for the purpose of curing their own delinquencies. And it provides a formal procedure which is' generally desirable for the Commissioner, collectors, and subordinates in the Department.””
5 later decisions quote this exact passage · from the majority“must honestly and reasonably be intended as such”
3 later decisions quote this exact passage · from the majority“* * * The burden of supplying by the return the information on which assessments were to be based was thus imposed upon the taxpayer. And, in providing that the period of limitation should begin on the date when the return was filed rather than when it was due, the statute plainly manifested a purpose that the period was to commence only when the taxpayer had supplied this information in the prescribed manner.”
2 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.