Price v. Commissioner’s Empirical Analysis
106 F.2d 336 · 1939
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 8 later decisions (2 by the Supreme Court) — most recently June 1970
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.
Appellate journey
Relationships
Relies on Burnet v. Logan · United States v. Mitchell · Eckert v. Burnet · Avery v. Commissioner · Hart 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The facts of the transaction concerned were that the petitioner and his-partner were joint endorsers of notes issued by a corporation that they had formed. There remained due upon these notes $44,800, that the corporation was unable to pay. In 1925 the petitioner and his partner in settlement of their liability made a joint note for that sum to the bank that held the corporation’s paper, received the old notes, ■ marked paid, and destroyed them. The petitioner claims the right to deduct half that sum as a debt ‘ascertained to be worthless and charged off within the taxable year’ under the Revenue Act of 1926, c. 27, § 214(a) (7), 44 Stat. 9 , 27. “It seems to us that the Circuit Court of Appeals sufficiently answered this contention by remarking that the debt was worthless when acquired. There was nothing to charge off. The petitioner treats the case a® one of an investment that later turns out to be bad. But in fact it was the satisfaction of an existing obligation of the petitioner, having, it may be, the consequence of a momentary transfer of the old notes to the petitioner in order that they might be destroyed. It is very plain we think that the words of the statute cannot be taken to include a case of that kind.””
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.