Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal Revenue’s Empirical Analysis
1975
Citation profile
125 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 439 later decisions — most recently June 2019 · most notably Weimerskirch v. Commissioner (1979), Wilcox v. Commissioner (1988)
125 federal appellate · 1 district · 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. § 1031 · 26 U.S.C. § 1202 · 26 U.S.C. § 269
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Helvering v. Taylor · O’Callahan v. Parker, Warden · Phillips v. Commissioner · Phillips 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 439 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The presumption in favor of the Commissioner is a procedural device which requires the taxpayer to come forward with enough evidence to support a finding contrary to the Commissioner's determination.”
10 later decisions quote this exact passage · from the majority“is a burden of persuasion; it requires * * * [the estate] to show the merits of * * * [its] claim by at least a preponderance of the evidence.”
6 later decisions quote this exact passage · from the majority“after satisfying the procedural burden of producing evidence to rebut the presumption in favor of the Commissioner, the taxpayer must still carry his ultimate burden of proof or persuasion.”
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.