American Bank and Trust Company v. Dallas County’s Empirical Analysis
1983
Citation profile
11 federal appellate · 6 district · 127 state decisions
How this case has been cited
Cited by 182 later decisions (13 by the Supreme Court) — most recently January 2017 · most notably Doe v. Durtschi (1986), First National Bank of Atlanta v. Bartow County Board of Tax Assessors (1985)
11 federal appellate · 6 district · 127 state decisions — followed in 24 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
Applies 12 U.S.C. § 548 · 31 U.S.C. § 3124
Relies on Consumer Product Safety Commission v. GTE Sylvania, Inc. · M'Culloch v. State of Maryland · Morton v. Mancari · Osborn v. President Directors and Company of the Bank of the United States · Lewis v. United States
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 182 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[A]ll stocks, bonds, Treasury notes, and other obligations of the United States, shall be exempt from taxation by or under State or municipal or local authority. This exemption extends to every form of taxation that would require that either the obligations or the interest thereon, or both, be considered, directly or indirectly, in the computation of the tax, except nondiscriminatory franchise or other nonproperty taxes in lieu thereof imposed on corporations and except estate taxes or inheritance taxes.” ( Pub. L. No. 86-346, 73 Stat. 622; see 31 U.S.C. sec. 742 (1976).)”
8 later decisions quote this exact passage · from the dissent“The 1959 amendment rejected and set aside this Court’s rather formalistic pre-1959 approach to § 3701. Under that approach, if a tax were imposed on a property interest or transaction separate from the ownership of federal obligations, the method by which the tax was computed was entirely irrelevant. ... Under the plain language of the 1959 amendment, however, the tax is barred regardless of its form if federal obligations must be considered, either directly or indirectly, in computing the tax.”
6 later decisions quote this exact passage“Prior to the 1959 amendment, franchise and estate and inheritance taxes measured by the value of federal obligations, like bank shares taxes, were upheld on the theory that the tax was levied on the franchise or the transfer of property, rather than on the ownership interest in the federal securities themselves. By expressly exempting franchise and estate and inheritance taxes from the amended [§ 742], Congress manifested its awareness that the new language would broaden significantly the prohibition as it had been construed by the courts. Congress must have believed that franchise and estate and inheritance taxes required federal obligations to “be considered, directly or indirectly, in the computation of the tax”; otherwise, the specific exemptions for these taxes would have been superfluous. There is no reason to conclude that shares taxes are any different. [463 U.S. at --, 103 S.Ct. at 3375 , 77 L.Ed.2d at 1079-1080 ]”
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.