Danbury, Inc. v. Olive’s Empirical Analysis
820 F.2d 618 · 1987
Citation profile
17 federal appellate · 5 district ·
How this case has been cited
Cited by 40 later decisions — most recently January 2018 · most notably Hays and Company v. Merrill Lynch Pierce Fenner & Smith Inc (1989), Poleto v. Consolidated Rail Corp. (1987)
17 federal appellate · 5 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) · 26 U.S.C. § 6501 · 26 U.S.C. § 7651 · 26 U.S.C. § 7701 · 26 U.S.C. § 882 · 26 U.S.C. § 931 · 48 U.S.C. § 1395 · 48 U.S.C. § 1397
Relies on Thorpe v. Housing Authority of Durham · Reading Co. v. Schweitzer · United States v. Schooner Peggy · Allied Chemical & Alkali Workers v. Pittsburgh Plate Glass Co. · Koshatka v. Philadelphia Newspapers, Inc.
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“This 1921 statute set up the “mirror tax” system that remains in use: “Virgin Islands” is in effect substituted for “United States” (and vice versa) in the Internal Revenue Code so that, to satisfy Virgin Islands tax obligations, an individual or corporation in the Virgin Islands pays taxes to the BIR equivalent to the taxes an individual or corporation under the same circumstances in the United States would pay to the Internal Revenue Service. * * * [Danbury, Inc. v. Olive, 820 F.2d 618, 620 (3d Cir. 1987).]”
2 later decisions quote this exact passage · from the majority“The ... proceeds of any taxes levied by the Congress on the inhabitants of the Virgin Islands, ... shall be covered into the treasury of the Virgin Islands, ... Provided, That the term "inhabitants of the Virgin Islands” as used in this section shall include all persons whose permanent residence is in the Virgin Islands, and such persons shall satisfy their income tax obligations under the applicable taxing statutes of the United States by paying their tax on income derived from all sources both within and outside the Virgin Islands into the treasury of the Virgin Islands ....”
1 later decision quote this exact passage · from the majority“For example, a corporation considered “domestic” in the United States but doing business in the Virgin Islands was required to submit a return to the BIR, paying tax on income from sources in the Virgin Islands, and to submit a return to the Internal Revenue Service, paying tax on worldwide income, with a foreign tax credit allowed for the tax paid to the Virgin Islands. The mirror system, with its two separate taxing jurisdictions, operated similarly for citizens of the United States who resided in the Virgin Islands. * * * [Danbury, Inc. v. Olive, supra at 621 .]”
1 later decision quote this exact passage · from the majoritye.g. Huff v. Commissioner
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.