Phillips v. Commissioner’s Empirical Analysis
1931
Citation profile
420 federal appellate · 70 district · 126 state decisions
How this case has been cited
Cited by 1,009 later decisions (68 by the Supreme Court) — most recently June 2019 · most notably Board of Regents of State Colleges v. Roth (1972), Mathews v. Eldridge (1976)
420 federal appellate · 70 district · 126 state decisions — followed in 34 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
Relies on Phillips v. Commissioner · Old Colony Trust Co. v. Commissioner · Crooks v. Harrelson · Ng Fung Ho v. White · Poe v. Seaborn
Cited together with Phillips v. Commissioner · Fuentes v. Shevin · Mathews v. Eldridge · Mitchell v. W. T. Grant Co. · Ewing v. Mytinger & Casselberry, Inc.
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 1,009 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where only property rights are involved, mere postponement of the judicial enquiry is not a denial of due process, if the opportunity given for the ultimate judicial determination of the liability is adequate.”
51 later decisions quote this exact passage · from the majority““The amounts of the following liabilities shall * * * be assessed, collected, and paid in the same manner * * * as in the case of a deficiency in a tax imposed by this chapter * * *: “(1) The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax * * * imposed lipón the taxpayer by this chapter.””
7 later decisions quote this exact passage · from the majority“[I]t has already been shown that the right of the United States to exact immediate payment and to relegate the taxpayer to a suit for recovery is paramount. The privilege of delaying payment pending immediate judicial review, by filing a bond, was granted by the sovereign as a matter of grace solely for the convenience of the taxpayer.”
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.