Lorenz v. United States’s Empirical Analysis
296 F.2d 746 · 1961
Citation profile
3 federal appellate · 2 district ·
How this case has been cited
Cited by 22 later decisions (2 by the Supreme Court) — most recently September 1998
3 federal appellate · 2 district ·
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. § 117 · 26 U.S.C. § 1235
Relies on Myers v. Comm'r · Hollander v. United States · Zacks v. United States · 170 F. Supp. 802 - Verckler v. United States
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) provides: “Unless a claim for credit or refund is filed by the taxpayer within three years from the time the return was filed by the taxpayer or within two years from the time the tax was paid, no credit or refund shall be allowed or made after the expiration of whichever of such periods expires the later. If no return is filed by the taxpayer, then no credit or refund shall be allowed or made after two years from the time the tax was paid, unless before the expiration of such period a claim therefor is filed by the taxpayer.””
2 later decisions quote this exact passage““So, payments under exclusive licenses received after the Myers decision in 1946 were taxable as capital gains; but after May 31, 1950, they were taxable as ordinary income; and then after the enactment of the Internal Revenue Code of 1954, they were again taxable as capital gains. “To remedy this anomaly, Congress on June 29, 1956, passed P.L. 629 ( 70 Stat. 404 ), which amended the Internal Revenue Code of 1939 to conform to Section 1235 of the Internal Revenue Code of 1954, and made its provisions applicable to all payments received after May 31, 1950.” 296 F.2d at 747 .”
1 later decision 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.