Page v. Commissioner’s Empirical Analysis
1995
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 34 later decisions — most recently February 2019 · most notably Parrish v. Commissioner (1999), Schladweiler v. Commissioner (2002)
7 federal appellate · 1 district ·
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. § 107 · 26 U.S.C. § 1402 · 26 U.S.C. § 170 · 26 U.S.C. § 446 · 26 U.S.C. § 501 · 26 U.S.C. § 6673 · 28 U.S.C. § 1912
Relies on North Star Steel Co. v. Thomas · Nebraska v. Wyoming · Liberty Mortgage Co. v. Frey · Bradford v. Commissioner · BW Parkway Associates Partnership 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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'Arithmetic precision was originally and exclusively in * * * [Mr. Gleason's] hands, and he had a statutory duty to provide it . . . [H]aving defaulted in his duty, he cannot frustrate the Commissioner's reasonable attempts by compelling investigation and recomputation under every means of income determination.'”
3 later decisions quote this exact passage · from the majoritye.g. Gleason v. Comm'r · Owen v. Comm'r“where the Commissioner makes the assessment without any foundation or supporting evidence”
2 later decisions quote this exact passage · from the majority“Where a taxpayer’s method of accounting does not accurately reflect income, the Commissioner may determine the taxpayer’s income under a method which does clearly reflect income .... [W]here the taxpayer files income tax returns which substantially understate income, an assessment of deficiency is necessarily an estimate. As long as the reconstruction method is reasonable and logical, [the taxpayer] may not complain of its inevitable inaccuracies.”
1 later decision 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.