Biddle v. Commissioner’s Empirical Analysis
302 U.S. 573 · 1938
Citation profile
111 federal appellate · 18 district · 22 state decisions
How this case has been cited
Cited by 345 later decisions (31 by the Supreme Court) — most recently May 2017 · most notably Higgins v. Commissioner (1941), Commissioner of Internal Revenue v. Idaho Power Company (1974)
111 federal appellate · 18 district · 22 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
reviewedBiddle v. Commissioner of Internal Revenue (from Second Circuit Court of Appeals)
Relationships
Relies on Burnet v. Harmel · Weiss v. Wiener · Iselin v. United States · Helvering v. New York Trust Co. · Crew Levick Co v. Commonwealth of Pennsylvania
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 345 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as used in our own revenue laws, has for most practical purposes a well understood meaning to be derived from an examination of the statutes which provide for the laying and collection of income taxes. It is that meaning which must be attributed to it as used in section . 21 The Treasury's own regulation acknowledges the distinction between the Commissioner's claim in this case, which implicates the act of state doctrine, and the ordinary Biddle-type inquiry, which does not. The regulation provides, in relevant part:”
6 later decisions quote this exact passage · from the majority“departmental rulings not promulgated by the Secretary [of the Treasury] are of little aid in interpreting a tax statute”
4 later decisions quote this exact passage · from the majority““The power to tax and to grant the credit resides in Congress, and it is the will of Congress which controls the application of provisions for credit.””
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.