Rohmer v. Commissioner’s Empirical Analysis
1945
Citation profile
5 federal appellate ·
How this case has been cited
Cited by 20 later decisions — most recently June 2011
5 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. § 214
Relies on Union Pacific Railroad v. Utterbach · Estate of Marton v. Commissioner · Berlin v. Commissioner · Cowan v. Fallbrook Public Utility District · Lang 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“At the time the licensing agreement was settled upon the parties apparently made no effort to segregate the value paid for the United States rights from that paid for the Canadian rights. The circulation figures do not furnish a sufficient basis upon which we could determine that any of the income was derived from sources outside the United States. Since there is no basis upon which we could properly make any allocation, it follows that the full amount must be deemed to be from sources within the United States.”
2 later decisions quote this exact passage“Sec. 211. Tax on Nonresident Alien Individuals.”
1 later decision quote this exact passage“(a) No United States business or office.—”
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.