Dobson v. Commissioner’s Empirical Analysis
320 U.S. 489 · 1943
Citation profile
1,080 federal appellate · 34 district · 54 state decisions
How this case has been cited
Cited by 1,715 later decisions (90 by the Supreme Court) — most recently September 2022 · most notably Commissioner v. Sunnen (1948), Commissioner of Internal Revenue v. Duberstein D Stanton (1960)
1,080 federal appellate · 34 district · 54 state decisions — followed in 10 states
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
reviewedHarwick v. Commissioner (from Eighth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 272
Relies on Helvering v. Clifford · Helvering v. National Grocery Co. · Sunshine Anthracite Coal Co. v. Adkins · Rochester Telephone Corporation v. United States
Cited together with Commissioner of Internal Revenue v. Scottish American Inv Co · Bingham's Trust v. Commissioner of Internal Revenue · Helvering v. Clifford · Commissioner of Internal Revenue v. Heininger · Gregory v. Helvering
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 1,715 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“`warrant in the record' and a reasonable basis in the law”
10 later decisions quote this exact passage · from the majority““Congress has invested the Tax Court with primary authority for redetermining deficiencies, which constitutes the greater part of tax litigation. This requires it to consider both law and facts. [W]hen the court cannot separate the elements of a decision so as to identify a clear-cut mistake of law, the decision of the Tax Court must stand. In view of the division of functions between the Tax Court and reviewing courts it is of course the duty of the Tax Court to distinguish with clarity between what it finds as fact and what conclusion it reaches on the law. In deciding law questions courts may properly attach weight to the decision of points of law by an administrative body having special competence to deal with the subject matter. The Tax Court is informed by experience and kept current with tax evolution and needs by the volume and variety of its work. While its decisions may not be binding precedents for courts dealing with similar problems, uniform administration would be promoted by conforming to them where possible.” (Accent added.)”
9 later decisions quote this exact passage · from the majority“Whether an apparently integrated transaction shall be broken up into several separate steps (as the majority was done) and whether what apparently are several steps shall be synthesized into one whole transaction is frequently a necessary determination in deciding tax consequences. Where no statute or regulation controls, the Tax Court's selection of the course to follow is no more reviewable than any other question of fact.”
4 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.