Jenkins v. Bitgood’s Empirical Analysis
101 F.2d 17 · 1939
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 21 later decisions (3 by the Supreme Court) — most recently February 1999
8 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
Applies 26 U.S.C. § 23
Relies on United States v. Phellis · Pinellas Ice & Cold Storage Co. v. Commissioner · United States v. Mitchell · Eckert v. Burnet · Burnet v. Huff
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The basis for determining the amount of deduction for a loss sustained under [§ 165] is the adjusted basis provided in [§§ 1016, 1017, 1018]. This provides that proper adjustment shall be made “for expenditures, receipts, losses, or other items, properly chargeable to capital account.” We do not see how a taxpayer on the cash basis can treat as an “expenditure” the mere incurring of a liability for a capital contribution. Not until the note is paid will he make an “expenditure” that increases the cost of his stock.”
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.