Podell v. Commissioner’s Empirical Analysis
1970
Citation profile
How this case has been cited
Cited by 35 later decisions — most recently November 2019 · most notably Brannen v. Commissioner (1982), Leahy v. Commissioner (1986)
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 O’Callahan v. Parker, Warden · Clark v. Sidway · Blackner v. McDermott · Tompkins v. Commissioner · Austin 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as if * * * [they] were realized directly from the source from which realized by the partnership * * *.”
2 later decisions quote this exact passage“special combination of two or more persons, where in some specific venture a profit is jointly sought without any actual partnership or corporate designation”
1 later decision quote this exact passage“It is the intent of the partnership and not that of any specific partner which is determinative in characterizing the income for purposes of taxation.”
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.