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← 60 TC 917 - Dougherty v. Commissioner

Dougherty v. Commissioner’s Empirical Analysis

1973

Citation profile

46
cited by 46 later decisions
1
states following
June 2022
most recently cited

3 federal appellate · 1 state decisions

How this case has been cited

Cited by 46 later decisions — most recently June 2022 · most notably United States v. Helmsley (1991), Smith v. Commissioner (1982)

3 federal appellate · 1 state decisions

230197319801990200020102020decided

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. § 131

Relies on Eisner v. Macomber · Brushaber v. Union Pacific Railroad · Corliss v. Bowers · Wichita Terminal Elevator Co. v. Commissioner · Wichita Terminal Elevator Co. 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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “the critical question * * * is whether 'the original action (or the failure to act) on the part of the taxpayer did not amount to an election against, and was not inconsistent with, the position which the taxpayer ultimately did adopt.'”
    1 later decision quote this exact passage · from the majority
    e.g. Grumbles
  2. “bond, note, debenture, certificate, bill receivable, account receivable, note receivable, open account, or other indebtedness, whether or not issued at a discount and whether or not bearing interest.”
    1 later decision quote this exact passage · from the majority
    e.g. Sherwood Properties v. Commissioner
  3. “to prevent the repatriation of income to the United States in a manner which does not subject it to U.S. taxation.”
    1 later decision quote this exact passage
    e.g. Sih Partners LLLP v. Comm'r of Internal Revenue

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.