Farrell v. United States’s Empirical Analysis
313 F.3d 1214 · 2002
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 22 later decisions — most recently July 2021
10 federal appellate ·
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. § 911 · 26 U.S.C. § 931 · 28 U.S.C. § 1291 · 48 U.S.C. § 1411 · 48 U.S.C. § 1421 (Guam Development Fund Act of 1968)
Relies on Oliver v. Keller · Specking v. Comm'r · Scofield v. Lewis · Cramer v. Commissioner
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Inasmuch as Johnston Island does not fall within the definition of a foreign country, the compensation [Taxpayers] earned on Johnston Island does not come within the definition of “foreign earned income”, nor was their “tax home” in a foreign country. Sec. 911(b)(1)(A) and (d). Consequently, [they] cannot satisfy the requirements for the exclusion from income provided by section 911.”
4 later decisions quote this exact passage · from the majority“SEC. 1277. EFFECTIVE DATE (a) IN GENERAL. — Except as otherwise provided in this section, the amendments made by this subtitle shall apply to taxable years beginning after December 31,1986. (b) SPECIAL RULE FOR GUAM, AMERICAN SAMOA, AND THE NORTHERN MARIANA ISLANDS.— The amendments made by this subtitle shall apply with respect to Guam, American Samoa, or the Northern Mariana Islands (and to residents thereof and corporations created or organized therein) only if (and so long as) an implementing agreement under section 1271 is in effect between the United States and such possession.”
3 later decisions quote this exact passage · from the majority“Relationship of sections 931 and 911. A citizen of the United States who cannot [qualify under] section 931 but who receives earned income from sources within a possession of the United States, is not deprived of the benefits of the provisions of section 911 (relating to the exemption of earned income from sources outside the United States), provided he meets the requirements thereof. In such a case none of the provisions of section 931 is applicable in determining the citizen’s tax liability....”
3 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.