Yagoda v. Commissioner’s Empirical Analysis
1962
Citation profile
4 federal appellate · 1 district ·
How this case has been cited
Cited by 36 later decisions — most recently March 2016 · most notably Yagoda v. Commissioner of Internal Revenue (1964), Neubecker v. Commissioner (1975)
4 federal appellate · 1 district ·
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 Sanford's Estate v. Commissioner of Internal Revenue · Swift Company v. Hocking Valley Railway Company · Public Utilities Commission v. Pollak · Rios v. United States · Scott 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““While the mitigation provisions might have been formulated in terms of the Commissioner’s or the taxpayer’s ability to correct the error when the inconsistency involved was first brought to his attention, they were not so written. Instead, all that the provisions of sections 1311-1314 require is that correction of the error is prevented by the operation of any law or rule of law when the determination becomes final (Sections 1311(a) and 1313(a) (1)) and that the notice of deficiency or claim for refund making the correcting adjustment be sent within one year after such determination becomes final (Section 1314(b)). These conditions were met in the present eases.””
1 later decision quote this exact passage““(3) Existence of relationship.— In case the amount of the adjustment would be assessed and collected in the same manner as a deficiency (except for cases described in section 1312(3) (B)), the adjustment shall not be made with respect to a related taxpayer unless he stands in such relationship to the taxpayer at the time the latter first maintains the inconsistent position in a return, claim for refund, or petition (or amended petition) to the Tax Court of the United States for the taxable year with respect to which the determination is made, or if such position is not so maintained, then at the time of the determination.””
1 later decision quote this exact passage · from the majority“up to an amount not in excess of what had been distributed to her”
1 later decision quote this exact passage · from the majoritye.g. Shockley v. Comm'r
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.