Stone v. Commissioner’s Empirical Analysis
1971
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 747 later decisions — most recently April 2020 · most notably Rowlee v. Commissioner (1983), Petzoldt v. Commissioner (1989)
8 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
Relies on Spies v. United States · Kercheval v. United States · Linkletter v. Walker · Otsuki v. Commissioner · Marchetti v. United States
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 747 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“its proof may depend to some extent upon circumstantial evidence, and may rest upon reasonable inferences properly drawn from the evidence of record.”
10 later decisions quote this exact passage“,(e) Spouse Relieved op Liability in Certain Cases. — ■ (1) In general. — under regulations prescribed by tbe Secretary or bis delegate, if — ■ (A) a Joint return bas been made under tbis section for a taxable year and on sueb return there was omitted from gross income an amount properly includable therein which is attributable to one spouse and which is in excess of 25 percent of the amount of gross income stated in the return, (B) the other spouse establishes that in signing the return he or she did not know of, and had no reason to know of, such omission, and (C) taking into account whether or not the other spouse significantly benefited directly or indirectly from the items omitted from gross income and taking into account all other facts and circumstances, it is inequitable to hold the other spouse liable for the deficiency in tax for such taxable year attributable to such omission,”
2 later decisions quote this exact passage““In the case of a joint return under section 6013, this subsection shall not apply with respect to the tax of a spouse unless some part of the underpayment is due to the fraud of such spouse.””
2 later decisions 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.