Heard v. Commissioner’s Empirical Analysis
1964
Citation profile
8 federal appellate · 1 district · 3 state decisions
How this case has been cited
Cited by 24 later decisions — most recently February 1995
8 federal appellate · 1 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.
Relationships
Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Commissioner of Internal Revenue v. Glenshaw Glass Company · Commissioner of Internal Revenue v. South Texas Lumber Co · Corn Products Refining Company v. Commissioner of Internal Revenue · Foti v. Immigration & Naturalization Service
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * all income from whatever source derived, including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items;””
2 later decisions quote this exact passage · from the majority“whether or not sec. 72 applies, the result is the same — i.e., the amount received under the Act in excess of the amount contributed to the retirement program by taxpayer is taxable income. [ 326 F.2d at 968 .]”
1 later decision quote this exact passage · from the majority“Gross income does not include the value of property acquired by gift, bequest, devise, or inheritance.”
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.