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← 293 U.S. 507 - Helvering v. Taylor

Helvering v. Taylor’s Empirical Analysis

293 U.S. 507 · 1935

Citation profile

3,194
cited by 3,194 later decisions
27
cited 27 times by the Supreme Court
6
states following
July 2020
most recently cited

1,434 federal appellate · 69 district · 15 state decisions

How this case has been cited

Cited by 3,194 later decisions (27 by the Supreme Court) — most recently July 2020 · most notably United States v. Janis (1976), Helvering v. Rankin (1935)

1,434 federal appellate · 69 district · 15 state decisions

55001935194019501960197019801990200020102020decided

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

reviewedTaylor v. Commissioner (from Second Circuit Court of Appeals)

Relationships

Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · United States v. Anderson · Gunning v. Cooley

Cited together with Welch v. Helvering · United States v. Janis · Holland v. United States · Commissioner of Internal Revenue v. Duberstein D Stanton · Lewis v. Reynolds

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 3,194 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Unquestionably the burden of proof is on the taxpayer to show that the Commissioner's determination is invalid.”
    45 later decisions quote this exact passage · from the majority
    e.g. Gasper v. Commissioner · Simon v. Commissioner
  2. “* * * Whether the Circuit Court of Appeals erred in remanding this case to the Board of Tax Appeals for a new hearing on the ground that the Commissioner's determination of the amount of income was incorrect, although the taxpayer had failed to prove facts from which a correct determination could be made.”
    3 later decisions quote this exact passage · from the majority
    e.g. Simon v. Commissioner · Sam Simon v. Commissioner of Internal Revenue, Albert Simon v. Commissioner of Internal Revenue, Clara Simon v. Commissioner of Internal Revenue, Melvin Simon v. Commissioner of Internal Revenue
  3. ““The burden of proof shall be upon the petitioner, except as otherwise provided by statute or determined by the Court; and except that, in respect of any new matter, increases in deficiency, and affirmative defenses, pleaded in his answer, it shall be upon the respondent.” (emphasis supplied)”
    3 later decisions quote this exact passage · from the majority
    e.g. Silverman v. Commissioner · Seymour Silverman v. Commissioner of Internal Revenue

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.