Samann v. Commissioner’s Empirical Analysis
1961
Citation profile
How this case has been cited
Cited by 8 later decisions — most recently August 2002
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. § 7805 · 26 U.S.C. § 894
Relies on Hauenstein v. Lynham · Jordan v. Tashiro · The Amiable Isabella · American Trust Co. v. Smyth · Ruud Manufacturing Co. v. Commissioner of Internal Revenue
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“has no permanent establishment within the United States at any time during the taxable year in which such income is so derived.”
1 later decision quote this exact passage“may prescribe regulations necessary to interpret and carry out the provisions of this convention.”
1 later decision quote this exact passage“a resident * * * of the other contracting State”
1 later decision quote this exact passage
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.