Commissioner v. Sunnen’s Empirical Analysis
333 U.S. 591 · 1948
Citation profile
2,138 federal appellate · 358 district · 396 state decisions
How this case has been cited
Cited by 5,752 later decisions (78 by the Supreme Court) — most recently February 2025 · most notably Parklane Hosiery Co. v. Shore (1979), Montana v. United States (1979)
2,138 federal appellate · 358 district · 396 state decisions — followed in 41 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
reviewedSunnen v. Commissioner (from Eighth Circuit Court of Appeals)
Relationships
Relies on Cromwell v. County of Sac · Helvering v. Clifford · Helvering v. Horst · Lucas v. Earl
Cited together with Cromwell v. County of Sac · Montana v. United States · Lawlor v. National Screen Service Corp. · Tait v. Western Maryland Railway Co. · 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 5,752 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“not only as to every matter which was offered and received to sustain or defeat the claim or demand, but as to any other admissible matter which might have been offered for that purpose.”
359 later decisions quote this exact passage · from the majority“The crucial question remains whether the assignor retains sufficient power and control over the assigned property or over receipt of the income to make it reasonable to treat him as the recipient of the income for tax purposes.”
15 later decisions quote this exact passage · from the majority“One vested with the right to receive income did not escape the tax by any kind of anticipatory arrangement, however skillfully devised, by which he procures payment of it to another, since, by the exercise of his power to command the income, he enjoys the benefit of the income on which the tax is laid.”
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.