Commissioner v. Smith’s Empirical Analysis
324 U.S. 177 · 1945
Citation profile
237 federal appellate · 12 district · 16 state decisions
How this case has been cited
Cited by 510 later decisions (10 by the Supreme Court) — most recently February 2020 · most notably James v. United States (1961), Bingham's Trust v. Commissioner of Internal Revenue (1945)
237 federal appellate · 12 district · 16 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
reviewedSmith v. Commissioner (from Ninth Circuit Court of Appeals)
Relationships
Relies on Old Colony Trust Co. v. Commissioner · Palmer v. Commissioner · Helvering v. San Joaquin Fruit & Investment Co. · Shuster 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 510 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Section 22(a) of the Revenue Act is broad enough to include in taxable income any economic or financial benefit * * *, whatever the form or mode by which it is effected.””
18 later decisions quote this exact passage · from the majority“It of course does not follow that in other circumstances not here present the option itself, rather than the proceeds of its exercise, could not be found to be the only intended compensation.”
11 later decisions quote this exact passage · from the majority““Since the Tax Court found that the market price of the stock on the date of the option did not exceed the option price, it is evident that its finding that the option was given as compensation for respondent’s services, had reference to the compensation to be derived from exercise of the option after the anticipated advance in market price of the stock.””
2 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.