Olsen v. Helvering’s Empirical Analysis
88 F.2d 650 · 1937
Citation profile
49 federal appellate · 1 district ·
How this case has been cited
Cited by 123 later decisions — most recently March 2020 · most notably Shea v. Commissioner (1999), Howard S. Scar and Ethel M. Scar v. Commissioner of Internal Revenue (1987)
49 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. § 272
Relies on Hulburd v. Commissioner · Commissioner v. New York Trust Co. · Burnet v. San Joaquin Fruit & Investment Co. · Haag v. Commissioner of Internal Revenue · Whitmer v. Lucas
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 123 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he notice is only to advise the person who is to pay the deficiency that the Commissioner means to assess him; anything that does this unequivocally is good enough.”
24 later decisions quote this exact passage · from the majority“(t)he taxpayer's petition ... makes it perfectly plain that he was not mislead ...”
2 later decisions quote this exact passage · from the majoritye.g. Tony Abatti and Sheila Gruis, Formerly Known as Sheila Abatti, Petitioners v. Commissioner of Internal Revenue, Tony Abatti v. Commissioner of Internal Revenue, Ben Abatti and Margaret L. Abatti v. Commissioner of Internal Revenue, Tony Abatti and Ninfa Abatti v. Commissioner of Internal Revenue, Ben Abatti and Margaret L. Abatti v. Commissioner of Internal Revenue · Abatti v. Commissioner“which do not frustrate its purpose, are negligible.”
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.