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← 4 BTA 5 - Warner Sugar Refining Co. v. Commissioner

Warner Sugar Refining Co. v. Commissioner’s Empirical Analysis

1926

Citation profile

19
cited by 19 later decisions
October 1962
most recently cited

1 federal appellate ·

How this case has been cited

Cited by 19 later decisions — most recently October 1962

1 federal appellate ·

11019261930194019501960decided

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 Girard Trust Co. v. United States · Shutte v. Thompson · Wells, Fargo & Co. v. Enright · Tavid Randon v. Thomas Toby · National Refining Co. 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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “It has long been recognized, both by the Commissioner and all of his predecessors, as well as taxpayers generally, that reconsiderations of liability to internal-revenue taxes were both proper and lawful. * * * The principle or rule of law to the effect that reconsiderations and adjustments of tax liability can be properly made seems to have been recognized by Congress * * * [citing sections 1309 and 1312, Revenue Act of 1921].”
    1 later decision quote this exact passage
  2. “No notice was ever served upon the Commissioner by the taxpayer prior to the assessment of the amount here in controversy as to when it would regard the provisions of the waiver as having been fully complied with by both parties and become inoperative.”
    1 later decision quote this exact passage
  3. “There is no provision in the various Revenue Acts which provides that the Commissioner may not make more than one assessment in respect of the tax for any year * * *.”
    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.