Commissioner of Internal Revenue v. J Kowalski’s Empirical Analysis
1977
Citation profile
102 federal appellate · 9 district · 18 state decisions
How this case has been cited
Cited by 290 later decisions (11 by the Supreme Court) — most recently June 2024 · most notably Rowan Cos. v. United States (1981), HCSC-Laundry v. United States (1981)
102 federal appellate · 9 district · 18 state decisions
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
reviewedSaunders v. Commissioner of Internal Revenue (from Third Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 119 · 26 U.S.C. § 162 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 37 U.S.C. § 101 (Armed Forces Enlisted Personnel Bonus Revision Act of 1974)
Relies on Helvering v. Clifford · Commissioner of Internal Revenue v. Glenshaw Glass Company · Eisner v. Macomber · United States v. Correll · Helvering v. Winmill
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 290 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“gross income means all income from whatever source derived, including (but not limited to) the following items: (1) Compensation for services, including fees, commissions, and similar items....”
6 later decisions quote this exact passage · from the dissent“* * * [Arguments of equity have little force in construing the boundaries of exclusions and deductions from income many of which, to be administrable, must be arbitrary. * * *”
5 later decisions quote this exact passage · from the majority“all gains except those specifically exempted.”
4 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.