Pursell v. Commissioner’s Empirical Analysis
1962
Citation profile
13 federal appellate ·
How this case has been cited
Cited by 55 later decisions — most recently July 2006 · most notably Electric & Neon, Inc. v. Commissioner (1971), Mecom v. Commissioner (1993)
13 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 Commissioner v. Dwyer · Commissioner v. Schuyler · Welp v. United States · Ezo Products Co. v. Commissioner · Commissioner v. Frame
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“refers only to time, and leaves the parties free to decide for themselves the terms on which an extension will be granted.”
3 later decisions quote this exact passage · from the majority“to prevent income from escaping tax altogether and to prevent double taxation of income where such escape or doubling up resulted solely from a change in method of computing taxable income”
2 later decisions quote this exact passage · from the majority“A change in the method of accounting initiated by the taxpayer includes not only a change which he originates by securing the consent of the Commissioner, but also a change from one method of accounting to another made without the advance approval of the Commissioner. A change in the taxpayer's method of accounting required as a result of an examination of the taxpayer's income tax return will not be considered as initiated by the taxpayer. On the other hand, a taxpayer who, on his own initiative, changes his method of accounting in order to conform to the requirements of any Federal income tax regulation or ruling shall not, merely because of such fact, be considered to have made an involuntary change.”
1 later decision 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.