Austin Co. v. Commissioner’s Empirical Analysis
35 F.2d 910 · 1929
Citation profile
38 federal appellate · 4 district ·
How this case has been cited
Cited by 54 later decisions (1 by the Supreme Court) — most recently January 1997 · most notably Daube v. United States (1933), United States v. Lease (1965)
38 federal appellate · 4 district ·
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. § 1061 (§ 13309 of the Tax Cuts and Jobs Act of 2017)
Relies on United States v. Chemical Foundation, Inc. · Gould v. Gould · Wickwire v. Reinecke · Williamsport Wire Rope Co. v. United States · Blair v. Oesterlein Machine Co.
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 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Even though there was lack of authority to make such assessment upon a changed view of the same facts, there was not lack of authority to make it where there was fraud or mistake of law or fact in the original assessment. In this situation the burden was on the petitioner to show that the commissioner’s action grew out of circumstances which did not warrant it.””
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.