Kronish v. Commissioner’s Empirical Analysis
1988
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 113 later decisions — most recently December 2019 · most notably Woods v. Commissioner (1989), Norfolk Southern Corp. v. Commissioner (1995)
3 federal appellate ·
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
Relies on Wichita Terminal Elevator Co. v. Commissioner · Wichita Terminal Elevator Co. v. Commissioner · Stange v. United States · Pimpinello v. Swift & Co. · Estate of Emerson v. Commissioner
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 113 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is the objective manifestation of mutual assent as evidenced by the parties' overt acts, not the parties' secret intentions, that determines whether the parties have made an agreement.”
4 later decisions quote this exact passage“Extension by agreement. — -Where, before the expiration of the time prescribed in this section for the assessment of any tax imposed by this title, except the estate tax provided in chapter 11, both the Secretary and the taxpayer have consented in writing to its assessment after such time, the tax may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon.”
3 later decisions quote this exact passage“Contract principles are significant, however, because section 6501(c)(4) requires that the parties reach a written agreement as to the extension.”
2 later decisions quote this exact passagee.g. Aronson v. Commissioner · Bower
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.