Commissioner v. Stern’s Empirical Analysis
1958
Citation profile
301 federal appellate · 42 district · 6 state decisions
How this case has been cited
Cited by 916 later decisions (19 by the Supreme Court) — most recently January 2020 · most notably Aquilino v. United States (1960), United States v. Rodgers (1983)
301 federal appellate · 42 district · 6 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
reviewedStern v. Commissioner (from Sixth Circuit Court of Appeals)
Relationships
Applies 11 U.S.C. § 110 · 26 U.S.C. § 311 · 26 U.S.C. § 811
Relies on Erie Co v. Tompkins · Textile Workers v. Lincoln Mills of Ala. · Clearfield Trust Co. v. United States · Burnet v. Harmel · Morgan v. Commissioner
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 916 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“shall * * * be assessed, paid, and collected in the same manner and subject to the same provisions and limitations as in the case of the taxes with respect to which the liabilities were incurred”
9 later decisions quote this exact passage · from the majority“[T]he existence and extent of liability should be determined by state law.”
7 later decisions quote this exact passage · from the majority““(a) Method of collection. The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same provisions and limitations as in the case of a deficiency in a tax imposed by this chapter (including the provisions in case of delinquency in payment after notice and demand, the provisions authorizing distraint and proceedings in court for collection, and the provisions prohibiting claims and suits for refunds): “(1) Transferees. The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax (including interest, additional amounts, and additions to the tax provided by law) imposed upon the taxpayer by this chapter.””
6 later decisions quote this exact passage · from the dissent
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.