Rowlee v. Commissioner’s Empirical Analysis
1983
Citation profile
11 federal appellate · 1 district ·
How this case has been cited
Cited by 894 later decisions — most recently November 2023 · most notably Petzoldt v. Commissioner (1989), DiLeo v. Commissioner (1991)
11 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. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Hoffman v. United States · Spies v. United States · Eisner v. Macomber · Helvering v. Mitchell · Joseph Lochner v. People of the State of New York
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 894 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“all income from whatever source derived,”
10 later decisions quote this exact passage · from the majority“Although the wages [gross income] received by [petitioner] may represent no more than the time-value of his work, they are nonetheless the fruit of his labor, and therefore represent gain derived from labor which may be taxed as income”
5 later decisions quote this exact passage · from the majority“intended to evade taxes known to be owing by conduct intended to conceal, mislead, or otherwise prevent the collection of such taxes.”
5 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.