McIlhenny v. Commissioner’s Empirical Analysis
39 F.2d 356 · 1930
Citation profile
20 federal appellate · 5 district · 1 state decisions
How this case has been cited
Cited by 48 later decisions (1 by the Supreme Court) — most recently December 2002 · most notably Burnet v. Porter (1931), Boulez v. Commissioner (1987)
20 federal appellate · 5 district · 1 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.
Relationships
Applies 26 U.S.C. § 1249
Relies on Botany Worsted Mills v. United States · Woodworth v. Kales · Austin Co. v. Commissioner · L. Loewy & Son, Inc. v. Commissioner · Holmquist v. Blair
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Numerous complaints from various sources have reached me that taxpayers are being subjected to examinations and requests for information concerning cases in which the audits have been completed and the cases closed. Such examinations are not advisable and are clearly contrary to the spirit of the act and the regulations of the Department. The reopening of closed cases should be the rare exception and not the rule. In the absence of evidence of fraud or gross error cases once closed are not to be reopened.”
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.