Underhill v. Commissioner’s Empirical Analysis
1966
Citation profile
5 federal appellate · 1 district ·
How this case has been cited
Cited by 36 later decisions — most recently June 2025 · most notably Standard Oil Co. v. Commissioner (1981), Dearborn Gage Co. v. Commissioner (1967)
5 federal appellate · 1 district ·
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 Burnet v. Sanford & Brooks Co. · Burnet v. Logan · Drews v. Maryland · Ross v. Commissioner · United States v. El Paso Natural Gas Co.
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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.”
2 later decisions quote this exact passage“had no choice in determining whether an obligation was speculative or nonspeculative, nor was there any doubt or choice about the method or time of reporting income once that determination was made.”
1 later decision quote this exact passage“withdraw into an ivory tower, ignore the economic realities of the marketplace, and make all the assumptions in his [petitioner's] favor.”
1 later decision quote this exact passage
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.