Patterson v. Sims’s Empirical Analysis
281 F.2d 577 · 1960
Citation profile
13 federal appellate ·
How this case has been cited
Cited by 40 later decisions — most recently July 2016 · most notably Mysse v. Commissioner (1972), Stein v. Commissioner (1962)
13 federal appellate ·
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
Applies 26 U.S.C. § 273 · 26 U.S.C. § 311
Relies on United States v. Bess · Commissioner v. Stern · Gordon, Rankin & Co. v. Tweedy · Caldwell v. King
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“State law is therefore not a determinant of transferee liability subsequent to the notice of the transferee assessment under Section 311. Rather, Section 294(b), Internal Revenue Code 1939, furnishes the applicable rule.”). So Patterson provides useful guidance even though it dealt with unpaid income taxes, not gift taxes. . The dissent is correct to note that”
2 later decisions quote this exact passage“assessed, collected, and paid in the same manner and subject to the same provisions and limitations as in the case of a deficiency in a tax imposed by this chapter…”
2 later decisions quote this exact passage“from the date of such notice and demand until it is paid.”
2 later decisions quote this exact passage
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.