White v. Hofferbert’s Empirical Analysis
1950
Citation profile
14 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 31 later decisions — most recently April 1998 · most notably Weible v. United States (1957), Sochurek v. Commissioner (1962)
14 federal appellate · 3 district · 1 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. § 116
Relies on Commissioner of Internal Revenue v. Culbertson · District of Columbia v. Murphy · In Re Revocation of Ancillary Letters Testamentary of the Estate of Newcomb · Ex Parte Allen · Foreign Trade Management Co. v. United States
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In the application of such provision [one year foreign residence], the tests as to whether a taxpayer is a resident of a foreign country or countries will be those generally applicable in ascertaining whether an alien is a resident of the United States."”
2 later decisions quote this exact passage · from the majority“[[Image here]] (2) Presence in foreign country for 17 months — In the case of an individual citizen of the United States who during any period of 18 consecutive months is present in a foreign country or countries during at least 510 full days in such period, amounts received from sources without the United States (except amounts paid by the United States or any agency thereof) which constitute earned income attributable to services performed during such 18-month period. The amount excluded under this paragraph for any taxable year shall be computed by applying the special rules contained in subsection (c).”
1 later decision quote this exact passage · from the majority““On hearing the taxpayer’s extended testimony I found him a highly creditable and very well informed witness, and have no difficulty in finding his expression of intentions with regard to his foreign residence were in entire good faith. There is not the slightest suggestion in the case of any attempt by him to evade taxes. His foreign residence was solely due to the important business interests of the I. T. & T. in European countries. His case seems fairly typical of many citizens of the United States who accept foreign service for American enterprises with large interests abroad.””
1 later decision 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.