Durovic v. Commissioner’s Empirical Analysis
1973
Citation profile
34 federal appellate · 1 state decisions
How this case has been cited
Cited by 111 later decisions — most recently September 2017 · most notably Petzoldt v. Commissioner (1989), Roberts v. Commissioner (1974)
34 federal appellate · 1 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.
Relationships
Applies 26 U.S.C. § 51 · 26 U.S.C. § 6012 · 26 U.S.C. § 6013 · 26 U.S.C. § 6031 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6501 · 26 U.S.C. § 6651 · 26 U.S.C. § 6861
Relies on Cohan v. Commissioner · Automobile Club of Mich. v. Commissioner · Barr v. United States · Commissioner of Internal Revenue v. Lane-Wells Co · Germantown Trust Co. 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 111 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as the result of a failure to file a return, the Commissioner has been required to make an election for the taxpayers * * * that election may not thereafter be altered.”
5 later decisions quote this exact passage · from the majority“Congress has given discretion to the Commissioner to prescribe by regulation forms of returns and has made it the duty of the taxpayer to comply. It thus implements the system of self-assessment which is so largely the basis of our American scheme of income taxation. The purpose is not alone to get tax information in some form but also to get it with such uniformity, completeness, and arrangement that the physical task of handling and verifying returns may be readily accomplished. * * *”
3 later decisions quote this exact passage · from the majority“(b) Joint return after filing separate return. — (1) In general. — Except as provided in paragraph (2), if an individual has filed a separate return for a taxable year for which a joint return could have been made by him and his spouse under subsection (a) and the time prescribed by law for filing the return for such taxable year has expired, such individual and his spouse may nevertheless make a joint return for such taxable year.”
3 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.