Cole v. Commissioner’s Empirical Analysis
1958
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 24 later decisions — most recently April 1997
4 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. § 272
Relies on Saigh v. Commissioner · Dolezilek v. Commissioner · Joseph T. Miller and Crystal v. Miller v. Commissioner of Internal Revenue · Theron C. Teel and Lynn W. Teel v. Commissioner of Internal Revenue · Baker 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But where, for whatever reason, the parties are not in agreement at the time the case is called for trial, it is wholly irrelevant in this connection that they may have been in agreement at some earlier time. The inquiry into whether respondent’s Chief Counsel had “signed” the stipulations in this case is therefore beside the point. Furthermore, the mere signing of a paper, while retaining custody of it, does not necessarily render it an operative document. Until it is delivered or until some appropriate action is taken with respect thereto, it is far from clear that the signer may not scratch out his signature.”
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.