Douglas A. Page and Carolyn Page v. Commissioner of Internal Revenue’s Empirical Analysis
1987
Citation profile
15 federal appellate · 2 state decisions
How this case has been cited
Cited by 33 later decisions — most recently June 2014 · most notably Durkin v. Commissioner (1989), Page v. Commissioner (1995)
15 federal appellate · 2 state decisions
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. § 170 · 26 U.S.C. § 6653 · 26 U.S.C. § 7481 · 26 U.S.C. § 7483
Relies on Anderson v. City of Bessemer City · Welch v. Helvering · Browder v. Director Department of Corrections of Illinois · Lemon v. Kurtzman · Widmar v. Vincent
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A basic principle of tax law is that income is taxable to the one who earns it. It is likewise basic that a taxpayer is not relieved of his obligation to pay income tax on any income he earns when he transfers it or assigns it to another person or entity. If, however, one receives income as an agent for a principal, it is the income of the principal and not that of the agent. Specifically, if a member of a religious order earns income as an agent of and on behalf of the order, and gives that money to the order pursuant to his vow of poverty, that sum becomes income to the order and the individual is not taxed on it. Conversely, if a member of a religious order earns income in his individual capacity and gives the money to the order pursuant to his vow of poverty, that sum is income to him and is subject to federal income tax.”
1 later decision quote this exact passage · from the majority“was not an organization of the type described in section 170(c)(2). Petitioner was unsuccessful in Page I and the essence of our holding was: Although petitioners in this case were more meticulous in their execution of pro forma and other documents and in organizing and operating their”
1 later decision quote this exact passage · from the majoritye.g. Page v. Commissioner“[e]ven though the wages and income of [Page] were moved through an account which was denominated in the name of a church, payments from the account or from cash on hand were almost exclusively for personal living expenses,”
1 later decision quote this exact passage · from the majoritye.g. Page 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.