Palmer v. Webster & Atlas National Bank’s Empirical Analysis
312 U.S. 156 · 1941
Citation profile
39 federal appellate · 17 district · 3 state decisions
How this case has been cited
Cited by 150 later decisions (16 by the Supreme Court) — most recently February 2020 · most notably Group of Institutional Investors v. Chicago, Milwaukee, St. Paul & Pacific Railroad (1943), Spiegel's Estate v. Commissioner of Internal Revenue (1949)
39 federal appellate · 17 district · 3 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
reviewedWebster & Atlas Nat. Bank v. Palmer (from Second Circuit Court of Appeals)
Relationships
Relies on Philadelphia Co. v. Dipple · Warren v. Palmer · Erb v. Morasch · United States v. Harris
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 150 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Any officers and agents conducting any business under the authority of a United States court shall be subject to all Federal, State and local taxes applicable to such business to the same extent as if it were conducted by an individual or corporation.””
6 later decisions quote this exact passage · from the majority“(a) Trustees, receivers or managers of any property, including debtors in possession, may be sued, without leave of the court appointing them, with respect any of their acts or transactions in carrying on business connected with such property.... (b) ... [A] trustee, receiver or manager appointed in any case pending in any court of the United States, including a debtor in possession, shall manage and operate the property in his possession as such trustee, receiver or manager according to the requirements of the valid laws of the State in which such property is situated, in the same manner that the owner or possessor thereof would be bound to do if in possession thereof.”
3 later decisions quote this exact passage · from the majority““The legislative history of the Act discloses its purpose. The committee reports accompanying the bill which became the Act of 1934 state: ‘The purpose of this bill is to subject businesses conducted under receivership in Federal court to State and local taxation the same as if such businesses were being conducted by private individuals or corporations.’ The reports advert to the fact that federal courts had held a federal receiver operating a business exempt from state sales taxes. They conclude: ‘No good reason is perceived why a receiver should be permitted to operate under such an advantage as against his competitors not in receivership, and the State and local governments be deprived of this revenue.’ “What Congress intended was that a business in receivership, or conducted under court order, should be subject to the same tax liability as the owner would have been if in possession and operating the enterprise. * # *»”
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.