United States v. Updike’s Empirical Analysis
281 U.S. 489 · 1930
Citation profile
214 federal appellate · 35 district · 12 state decisions
How this case has been cited
Cited by 412 later decisions (28 by the Supreme Court) — most recently January 2021 · most notably Phillips v. Commissioner (1931), Old Colony Co v. Commissioner of Internal Revenue (1932)
214 federal appellate · 35 district · 12 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
reviewedUnited States v. Updike (from Eighth Circuit Court of Appeals)
Relationships
Relies on Bowers v. New York & Albany Lighterage Co. · United States v. Updike · United States v. Updike
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 412 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Indeed, when used to connote payment of a tax, it puts no undue strain upon the word ‘taxpayer’ to bring within its meaning that person whose property, being impressed with a trust to that end, is subjected to the burden. Certainly it would be hard to convince such a person that he had not paid a tax.””
5 later decisions quote this exact passage · from the majority““It seems plain enough, without stopping to cite authority, that the present suit, though not against the corporation but against its transferees to subject assets in their hands to the payment of the tax, is in every real sense a proceeding in court to collect a tax. The tax imposed upon the corporation is the basis of the liability, whether sought to be enforced directly against the corporation or by suit against its transferees. The aim in the one case, as in the other, is to enforce a tax liability; * * (emphasis supplied)”
3 later decisions quote this exact passage · from the majority““The amounts of the following liabilities shall * * * be assessed, collected, and paid in the same manner * * * as in the case of a deficiency in a tax imposed by this chapter * * *: “(1) The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax * * * imposed lipón the taxpayer by this chapter.””
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.