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← 423 F.2d 157 - Poorbaugh v. United States

Poorbaugh v. United States’s Empirical Analysis

423 F.2d 157 · 1970

Citation profile

14
cited by 14 later decisions
May 2008
most recently cited

4 federal appellate ·

How this case has been cited

Cited by 14 later decisions — most recently May 2008

4 federal appellate ·

601970198019902000decided

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. § 446 · 26 U.S.C. § 691

Relies on Doyle v. Mitchell Bros. · Pacific Nat Co v. Welch · Helvering v. Enright's Estate · Sullenger v. Commissioner · Commissioner v. O. Liquidating Corp.

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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “SEC. 691(a). Inclusion in Gross Income.— (1) GENERAL RULE. — The amount of all items of gross income in respect of a decedent which are not properly includible in respect of the taxable period in which falls the date of his death or a prior period * * * shall be included in the gross income, for the taxable year when received, of: (A) the estate of the decedent, if the right to receive the amount is acquired by the decedent's estate from the decedent * * * [Emphasis added.]”
    1 later decision quote this exact passage · from the majority
  2. “issue before us is the extent to which payments received by the petitioner are taxable or nontaxable i. e., the character of the payment not the proper method or time of reporting an item the character of which is not in question.”
    1 later decision quote this exact passage · from the majority
  3. “no authority for the proposition that because an erroneous accounting method was adopted by the taxpayer he should not be subject to the tax consequences resulting from that method absent a consent to change it.”
    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.