Robert H. Welch and Rosa Lena Welch v. Commissioner of Internal Revenue’s Empirical Analysis
1961
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 27 later decisions — most recently July 1994 · most notably Harbin v. Commissioner (1963), Barnes v. Commissioner (1969)
12 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
Relies on Helvering v. Taylor · Clark v. Commissioner · Harp v. Commissioner · Gasper v. Commissioner · Underwood 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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Unquestionably the burden of proof is on the taxpayer to show that the commissioner's determination is invalid. * * * But, where as in this case the taxpayer's evidence shows the commissioner's determination to be arbitrary and excessive, it may not reasonably be held that he is bound to pay a tax that confessedly he does not owe, unless his evidence was sufficient also to establish the correct amount that lawfully might be charged against him. On the facts shown by the taxpayer in this case, the board should have held the apportionment arbitrary and the commissioner's determination invalid.”
1 later decision 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.