Heiner v. Mellon’s Empirical Analysis
304 U.S. 271 · 1938
Citation profile
114 federal appellate · 6 district · 2 state decisions
How this case has been cited
Cited by 265 later decisions (32 by the Supreme Court) — most recently June 2024 · most notably Commissioner of Internal Revenue v. Estate J Bosch Second National Bank of New Haven (1967), Morgan v. Commissioner (1940)
114 federal appellate · 6 district · 2 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
reviewedHeiner v. Mellon (from Third Circuit Court of Appeals)
Relationships
Relies on Burnet v. Harmel · Corliss v. Bowers · Burnet v. Sanford & Brooks Co. · Palmer v. Bender · Stone v. White
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 265 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The tax is thus imposed upon the partner’s proportionate share of the net income of the partnership, and the fact that it may not be currently distributable, whether by agreement of the parties or by operation of law, is not material.””
7 later decisions quote this exact passage · from the majority“by express language or necessary implication, makes its own operation dependent upon state law.”
3 later decisions quote this exact passage · from the majority““ * * * The federal income tax system is based on an annual accounting. [Footnote omitted] Under that law the question whether taxable profits have been made is determined annually by the result of the operations of the year.” 304 U.S. at 275 , 58 S.Ct. at 928 .”
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.