Commissioner v. Tower’s Empirical Analysis
327 U.S. 280 · 1946
Citation profile
991 federal appellate · 41 district · 28 state decisions
How this case has been cited
Cited by 2,106 later decisions (25 by the Supreme Court) — most recently August 2022 · most notably Commissioner v. Sunnen (1948), Commissioner of Internal Revenue v. Culbertson (1949)
991 federal appellate · 41 district · 28 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
reviewedTower v. Commissioner (from Sixth Circuit Court of Appeals)
Relationships
Relies on Welch v. Helvering · Gregory v. Helvering · Helvering v. Clifford · Helvering v. Horst · Commissioner of Internal Revenue v. Court Holding Co
Cited together with Commissioner of Internal Revenue v. Culbertson · Lusthaus v. Commissioner · Helvering v. Clifford · Gregory v. Helvering · Helvering v. Horst
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 2,106 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the simple expedient of drawing up papers,”
88 later decisions quote this exact passage · from the majority““And we have held that the dominant purposes of all sections of the revenue laws, including these, is ‘the taxation of income to those who earn or otherwise create the right to receive it and enjoy the benefit of it when paid.’ ””
3 later decisions quote this exact passage · from the majority“no genuine union for partnership business purposes was ever intended and that the husband earned the income”
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.