Evco v. Jones’s Empirical Analysis
1972
Citation profile
2 federal appellate · 1 district · 79 state decisions
How this case has been cited
Cited by 99 later decisions (13 by the Supreme Court) — most recently June 1999 · most notably Container Corp. of America v. Franchise Tax Board (1983), Japan Line, Ltd. v. County of Los Angeles (1979)
2 federal appellate · 1 district · 79 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.
Relationships
Relies on United States v. District Court · Western Live Stock v. Bureau of Revenue · Reardon v. Meacham · Adams Mfg Co v. Storen · Gwin, White & Prince, Inc. v. Henneford
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 99 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Our prior cases indicate that a State may tax the proceeds from services performed in the taxing State, even though they are sold to purchasers in another State. Hence, in Department of Treasury v. Ingram-Richardson Mfg. Co., 313 U.S. 252 , 61 S.Ct. 866 , 85 L.Ed. 1313 , the Court upheld a state gross income tax imposed on a taxpayer engaged in the process of enameling metal parts for its customers. We accepted the finding of the court below that this was a tax on income derived from services, not from the sales of finished products, and we found irrelevant the fact that the sales were made to out-of-state customers. The tax was validly imposed on the service performed in the taxing State. See also Western Live Stock v. Bureau of Revenue, 303 U.S. 250 , 58 S.Ct. 546 , 82 L.Ed. 823 , 115 A.L.R. 944 .””
2 later decisions quote this exact passage · from the majority“neither this Court nor this Nation can ensure full apportionment when one of the taxing entities is a foreign sovereign. If an instrumentality of commerce is domiciled abroad, the country of domicile may have the right, consistently with the custom of nations, to impose a tax on its full value. If a State should seek to tax the same instrumentality on an apportioned basis, multiple taxation inevitably results. . . . Due to the absence of an authoritative tribunal capable of ensuring that the aggregation of taxes is computed on no more than one full value, a state tax, even though 'fairly apportioned' to reflect an instrumentality's presence within the State, may subject foreign commerce ' "to the risk of a double tax burden to which [domestic] commerce is not exposed, and which the commerce clause forbids.”
1 later decision quote this exact passage · from the majority“includes in its measure, without apportionment, receipts derived from activities in interstate commerce”
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.