Dotson v. United States’s Empirical Analysis
87 F.3d 682 · 1996
Citation profile
19 federal appellate · 3 district · 4 state decisions
How this case has been cited
Cited by 49 later decisions — most recently April 2016 · most notably Green v. Commissioner (2007), Murphy v. Internal Revenue Service (2007)
19 federal appellate · 3 district · 4 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. § 104 · 26 U.S.C. § 3101 (Federal Insurance Contributions Act) · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1140 (§ 510 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1144 (§ 514 of the Employee Retirement Income Security Act of 1974)
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Ingersoll-Rand Co. v. McClendon · Varity Corporation v. Howe · Mertens v. Hewitt Associates · Harper v. Virginia Department of Taxation
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The characterization of damages received is not affected by the shifting sands of statutory interpretation after a bona fide settlement has been reached or a damage award rendered____ The characterization of settlement depends upon the determination that the damages were received “through prosecution of a legal suit or action based upon tort or tort-type rights ...” Treasury Reg. 26 C.F.R. 1.104-1 (c). The fact that such a remedy may no longer exist is irrelevant to the determination of the character of a settlement to be taxed. Although the Supreme Court’s decision in Mertens may retroactively apply to pending ERISA cases, this case is not an ERISA case. It is an income tax case involving the tax treatment of a final settlement of a claim for damages under ERISA that was concluded before the issue of first impression decided by the sharply divided Mertens court was even clearly foreshadowed. Consequently, Mer-tens does not change the classification of the instant settlement for tax purposes any more than it could retroactively reduce the amount of the settlement which the parties made based on their now perhaps outmoded interpretation of ERISA law.”
3 later decisions quote this exact passage · from the majority“'the claim the parties, in good faith, intended to settle for.'”
3 later decisions quote this exact passage · from the majority“the district court should determine the degree to which the award represented lost wages for Mr. Dotson, since the record shows that he actually saw an increase in earnings at his next job. Once the district court distinguishes future lost wages from other potential parts of the Earnings Impairment Additur, it must also determine the nature of that award, and the degree to which the award envisioned earnings impairment as a result of the firing, and thus taxable, or instead, “on account of personal injuries” such as emotional damage or loss of reputation. Any part of the future lost wages attributable to causation by personal injury is excludable.”
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.