Gunkle v. Commissioner’s Empirical Analysis
753 F.3d 502 · 2014
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 170 · 26 U.S.C. § 501 · 26 U.S.C. § 6662 · 26 U.S.C. § 7483
Relies on Maryland Casualty Co. v. United States · Webb v. Commissioner · Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De Filipinas · Carson v. United States · Price 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Income received by the agent of a principal is deemed to be the income of the principal and not the income of the agent. It follows that income received by a member of a religious order as the agent of the order, promptly delivered to the order based on the agent’s vow of poverty, is deemed to be the income of the order and not of the agent. Conversely, however, a member of a religious order who earns or receives income therefrom in his individual capacity cannot avoid taxation on that income merely by taking a vow of poverty and assigning the income to that religious order or institution. The same rule applies to entities organized as corporation soles. [A]n individual has received income when he gains complete dominion and control over money or other property, thereby realizing an economic benefit.”
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.