Stein v. Commissioner’s Empirical Analysis
1962
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 71 later decisions — most recently November 2018 · most notably Edelson v. Commissioner (1987), Mysse v. Commissioner (1972)
7 federal appellate ·
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
Relies on Flora v. United States · North American Oil Consolidated v. Burnet · Commissioner v. Stern · Healy v. Commissioner · United States v. Lewis
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 71 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * In cases where the transferred assets exceed the total liability of the transferor, the interest being-charged is upon the deficiency, and is therefore a right created by the Internal Revenue Code. However, where, as here, the transferred assets are insufficient to pay the transferor’s total liability, interest is not assessed against the deficiencies because the transferee’s liability for such deficiencies is limited to the amount actually transferred to him. Interest may be charged against the transferee only for the use of the transferred assets, and since this involves the extent of transferee liability, it is determined by State law. * * *”
3 later decisions quote this exact passage“measured from a point of time that would not be earlier than the date of transfer”
2 later decisions quote this exact passage“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 ...): (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.”
1 later decision quote this exact passage · from the majoritye.g. Schussel v. Werfel
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.