Harris v. Commissioner’s Empirical Analysis
1973
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 14 later decisions — most recently September 2012
9 federal appellate ·
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. § 451
Relies on Griffiths v. Helvering · City Bank Farmers Trust Co. v. McGowan · Pike v. Wachovia Bank and Trust Company · Williams v. United States · Pozzi 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Sale proceeds, or other income, are constructively received when available without restriction at the taxpayer’s command; the fact that the taxpayer has arranged to have the sale proceeds paid to a third party and that the third party is, with [the] taxpayer’s agreement, not legally obligated to pay them to taxpayer until a later date, is immaterial.”
1 later decision quote this exact passage“Income although not actually reduced to a taxpayer's possession is constructively received by him in the taxable year during which it is credited to his account, set apart for him, or otherwise made available so that he may draw upon it at any time”
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.