Martin v. Commissioner’s Empirical Analysis
1985
Citation profile
63 federal appellate · 1 district ·
How this case has been cited
Cited by 98 later decisions — most recently September 2019 · most notably Wrenn v. Gould (1987), Dallo v. Immigration & Naturalization Service (1985)
63 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. § 7482 · 28 U.S.C. § 1912
Relies on Brushaber v. Union Pacific Railroad · Washington Post Co. v. Rebozo · Cochran v. United States · Rowlee v. Commissioner · Commissioner v. Acker
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 98 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“will not hesitate to award damages when the appeal is frivolous, or taken merely for purposes of delay, involving an issue or issues already 'clearly resolved'”
4 later decisions quote this exact passage · from the majority“If a court of appeals shall determine that an appeal is frivolous, it may award just damages and single or double costs to the appellee.”
4 later decisions quote this exact passage · from the majority“This argument is baseless. In Brushaber , the Court found the 1913 income tax law to be constitutional. The Court also noted that in Pollock [v. Farmers’ Loan and Trust Co., 158 U.S. 601 , 15 S.Ct. 912 , 39 L.Ed. 1108 (1895), a case that pre-dated the establishment of the federal income tax in 1913], it had previously found the taxing of income from professions, trades, employments or vocations to be constitutional in the form of an excise tax. In light of the sixteenth amendment, however, all taxation of income, “from whatever source derived,” was found to be constitutional in Brushaber . A multitude of cases following Brushaber have held that the type of revenues and receipts earned by appellant ... constitute taxable income under the Internal Revenue Code ... Appellant’s earnings, which are unchallenged here, constitute gross income under the applicable sections of the Internal Revenue Code. Appellant is therefore liable for income taxes, determined to be due....”
2 later decisions 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.