Simmons v. United States’s Empirical Analysis
308 F.2d 160 · 1962
Citation profile
13 federal appellate · 1 state decisions
How this case has been cited
Cited by 37 later decisions — most recently August 2014 · most notably Maurice M. Wills and Gertrude E. Wills v. Commissioner of Internal Revenue (1969), Murphy v. Internal Revenue Service (2007)
13 federal appellate · 1 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.
Relationships
Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Commissioner of Internal Revenue v. Glenshaw Glass Company · Eisner v. Macomber · Brushaber v. Union Pacific Railroad · James 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Gross income does not include amounts received as prizes and awards made primarily in recognition of religious, charitable, scientific, educational, artistic, literary or civic achievement, but only if— (1) the recipient was selected without any action on his part to enter the contest or proceeding; and (2) the recipient is not required to render substantial future services as a condition to receiving the prize or award.”
8 later decisions quote this exact passage“it has been clearly established that the labels used do not determine the extent of the taxing power”
2 later decisions quote this exact passage“gross income means all income from whatever source derived,”
2 later decisions 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.