United States v. Mitchell’s Empirical Analysis
1971
Citation profile
222 federal appellate · 27 district · 59 state decisions
How this case has been cited
Cited by 747 later decisions (15 by the Supreme Court) — most recently October 2020 · most notably United States v. Rodgers (1983), United States v. Craft (2002)
222 federal appellate · 27 district · 59 state decisions — followed in 14 states
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.
Appellate journey
reviewedAnne Goyne Mitchell v. Commissioner of Internal Revenue, Jane Isabell Goyne Sims v. Commissioner of Internal Revenue (from Fifth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 11
Relies on Commissioner of Internal Revenue v. Estate J Bosch Second National Bank of New Haven · Burnet v. Harmel · Morgan v. Commissioner · Blair v. Commissioner · United States v. Bess
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 747 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[F]ederal income tax liability follows ownership. In the determination of ownership, state law controls.”
19 later decisions quote this exact passage · from the majority“no property or rights to property shall be exempt from levy other than the property specifically made exempt by subsection (a).”
16 later decisions quote this exact passage · from the dissent“[W]ith respect to community income, as with respect to other income, federal income tax liability follows ownership. In the determination of ownership, state law controls.”
5 later decisions 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.