Commissioner of Internal Revenue v. Henry A. Kuckenberg, Transferee, Harriet Kuckenberg, Transferee, Lawrence W. Kuckenberg, Transferee, Henry A. Kuckenberg, Transferee, Harriet Kuckenberg, Transferee, Lawrence W. Kuckenberg, Transferee v. Commissioner of Internal Revenue’s Empirical Analysis
1962
Citation profile
34 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 66 later decisions — most recently August 2010 · most notably Schuster v. Commissioner (1962), Commissioner v. Anders (1969)
34 federal appellate · 1 district · 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. § 446
Relies on Helvering v. Horst · Commissioner of Internal Revenue v. Court Holding Co · Commissioner v. Stern · United States v. Cumberland Public Service Co. · Helvering v. Eubank
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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““‘[T]he corporation has performed the services which create the right to the income which brings into play the basic rule that income shall be taxed to him who earns it. Helvering v. Eubank, 1940, 311 U.S. 122 , 61 S.Ct. 149 , 85 L.Ed. 81 .’ ””
1 later decision quote this exact passage · from the majority“they assert that the United States does not have the status of a creditor since no ninety-day letter was sent to the corporation. However, the government need not take futile assessment action against a taxpayer without assets.”
1 later decision quote this exact passage · from the majority“expected . . . to follow the procedural intricacies of every one of the fifty states,”
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.