Rodney v. Comm'r’s Empirical Analysis
1969
Citation profile
3 federal appellate · 2 state decisions
How this case has been cited
Cited by 77 later decisions — most recently April 2016 · most notably Stone v. Commissioner (1971), Neonatology Assocs., P.A. v. Comm'r (2000)
3 federal appellate · 2 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
Relies on Commissioner v. Sunnen · Helvering v. Mitchell · Cree v. Goldstein · Tait v. Western Maryland Railway Co. · United States v. International Building Co.
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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[It is a] long-recognized legal principle that a husband and wife are separate and distinct taxpayers even where they have filed a joint Federal income tax return. ... [A] determination for a particular year against a husband who filed a joint return with his wife is not res judicata against the wife for the same year.... [A] wife who files a joint return with her husband is not a party privy to her husband in [income tax] litigation....””
2 later decisions quote this exact passage“It is not material that Arctic's conviction was based upon a guilty plea, because for purposes of applying the doctrine of collateral estoppel, as well as for other purposes, there is no difference between a judgment of conviction based upon such a plea and a judgment of conviction rendered after a trial on the merits. . . . Arctic's plea of guilty to this indictment was therefore a conclusive judicial admission that its return for 1946 was false and fraudulent and that the deficiency in tax which was the necessary result of its being filed was due to fraud with intent to evade tax.”
1 later decision quote this exact passage“If subsequent use will make a tentative election binding, we see no reason not to impute an election made in a year after the first year the property could properly be depreciated to the appropriate year where the taxpayer has inadvertently made an election in the wrong year. In either case, the taxpayer has had his opportunity to make his choice. It is the taxpayer’s choice of year that is in error, not his choice of method. * * * [ 53 T.C. at 317 .]”
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.