Rothensies v. Electric Storage Battery Co.’s Empirical Analysis
329 U.S. 296 · 1946
Citation profile
233 federal appellate · 58 district · 85 state decisions
How this case has been cited
Cited by 715 later decisions (10 by the Supreme Court) — most recently September 2020 · most notably United States v. Dalm (1990), Badaracco v. Commissioner (1984)
233 federal appellate · 58 district · 85 state decisions — followed in 19 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
reviewedElectric Storage Battery Co. v. Rothensies (from Third Circuit Court of Appeals)
Relationships
Relies on Bull v. United States · Order of Railroad Telegraphers v. Railway Express Agency, Inc. · Chase Securities Corp. v. Donaldson · Security Flour Mills Co. v. Commissioner · Stone v. White
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 715 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a single transaction constitute[s] the taxable event claimed upon and the one considered in recoupment.”
38 later decisions quote this exact passage · from the majority“[A]s statutes of limitation are applied in the field of taxation, the taxpayer sometimes gets advantages and at other times the Government gets them. Both hardships to the taxpayers and losses to the revenues may be pointed out”
32 later decisions quote this exact passage · from the majority““Sec. 6514(b) Credit After Period of Limitation. Any credit against a liability in respect of any taxable year shall be void if any payment in respect of such liability would be considered an overpayment under section 6401(a).” “Sec. 6401(a) Assessment and Collection After Limitation Period. The term ‘overpayment’ includes that part of the amount of the payment of any internal revenue tax which is assessed or collected after the expiration of the period of limitation properly applicable thereto.””
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.