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← 44 TC 420 - Dolan v. Commissioner

Dolan v. Commissioner’s Empirical Analysis

1965

Citation profile

67
cited by 67 later decisions
May 2017
most recently cited

6 federal appellate ·

How this case has been cited

Cited by 67 later decisions — most recently May 2017 · most notably Abeles v. Commissioner (1988), Cluck v. Commissioner (1995)

6 federal appellate ·

190196519701980199020002010decided

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 Bull v. United States · Burnet v. Harmel · United States v. Price · Lyeth v. Hoey · Hanover Bank 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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “if a joint return is made, the tax shall be computed on the aggregate income and the liability with respect to the tax shall be joint and several.”
    2 later decisions quote this exact passage · from the majority
  2. “[U]nder the parenthetical phrase in section 6211(a)(1)(B), the deficiencies in petitioner's tax would have been reduced by any amounts collected from [her spouse] prior to the mailing of the statutory notice to petitioner. The reason for this provision is that, even though [her spouse] and petitioner are jointly and severally liable for any deficiencies with respect to their joint returns, there is only one obligation for each year. Respondent is entitled to only one satisfaction of that obligation. Since payment by either spouse effects a pro tanto extinguishment of the obligation, the parenthetical phrase in section 6211(a)(1)(B) is wholly consistent with the joint and several liability of the spouses.”
    1 later decision quote this exact passage · from the majority
  3. “in the case of a deficiency in respect of a joint return, respondent may send separate notices or he may send a single joint notice; but if he wishes to send a joint notice and has been notified that the spouses have established separate residences, he must send a duplicate original of the joint notice to each spouse.”
    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.