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← 8 TC 637 - Wodehouse v. Commissioner

Wodehouse v. Commissioner’s Empirical Analysis

1947

Citation profile

9
cited by 9 later decisions
1
states following
June 2011
most recently cited

2 federal appellate · 1 state decisions

How this case has been cited

Cited by 9 later decisions — most recently June 2011

2 federal appellate · 1 state decisions

6019471950196019701980199020002010decided

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 Blair v. Oesterlein Machine Co. · Feeley v. Ragen · Rohmer v. Commissioner · Estate of Marton v. Commissioner · Capento Sec. Corp. 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The first issue, found also in the year 1938, presents the question of the taxability of lump sum payments for serial rights to literary works. Counsel for the petitioner (Wodehouse, the respondent here) concedes that substantially the same issue was raised and decided in Sax Rohmer, 5 T.C. 183; aff(irmed 2 Cir.), 153 F.2d 61, certiorari denied 328 U.S. 862 (66 S.Ct. 1367, 90 L.Ed. 1632). 9 "In Sax Rohmer, supra, we held that the lump sum payments for serial rights were royalties and, as such, were taxable to the recipient. The arguments advanced in the cases at bar follow the same pattern as those appearing in the Sax Rohmer case, as presented to this Court and to the Circuit Court of Appeals. The petitioner's contentions were rejected in both courts and for the same reasons stated in the opinions therein, they are rejected here.”
    1 later decision quote this exact passage
  2. “This check is offered and accepted with the understanding that The Curtis Publishing Company buys all rights in and of all stories and special articles appearing in its publications and with the further understanding that every number of these publications in which any portion thereof shall appear shall be copyrighted at its expense. After publication in a Curtis periodical is completed it agrees to reassign to the author on demand all rights, except American (including Canadian and South American) serial rights.”
    1 later decision quote this exact passage
  3. “The first issue, found also in the year 1938, presents the question of the taxability of lump sum payments for serial rights to literary works. Counsel for the petitioner (Wodehouse, the respondent here) concedes that substantially the same issue was raised and decided in Sax Rohmer, 5 T.C. 183; aff(irmed 2 Cir.), 153 F.2d 61, certiorari denied 328 U.S. 862 (66 S.Ct. 1367, 90 L.Ed. 1632). 9”
    1 later decision 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.