Smith v. Commissioner’s Empirical Analysis
1928
Citation profile
How this case has been cited
Cited by 8 later decisions — most recently April 1950
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 Dallas Country Levee District No. 2 v. Looney · Dallas County Levee Improvement Dist. No. 3 v. Ayers · Caldwell Milling Co. 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 petitioners contend, first, that the taxes in question are constitutional taxes for a public purpose and as such are deductible under section 214(a) (3) of the Revenue Act of 1921; and, second, that if they are not such taxes, then the amount thereof used for paying interest on the bonds is deductible under section 214(a) (2) of the 1921 Act as interest paid. We do not deem it necessary to go into the constitutional and statutory provisions of the law of Texas with reference to the taxes in question. The Supreme Court of Texas has held the payments to be taxes for local improvements cr, in other words, assessments. See Dallas County Levee District No. 2 v. Looney, 207 S. W. 310 ; Dallas County Levee Improvement District No. 3 v. Ayers et al., 246 S. W. 1112 . In Caldwell Milling Co., 3 B. T. A. 1232, the Board construed section 234(a) (3) (c) of the Revenue Act of 1918 to mean special or local assessments as a class and as such not deductible. Our reasoning therein applies with equal force to the provision of section 214(a) (3) (c) of the 1921 Act. It is clear, therefore, that petitioners’ first contention is unsound and can not be sustained. However, petitioners contend that that part of the assessment paid in 1923 which was used for the purpose of paying interest on the bonds issued by Houston Levee District No. 1 is deductible as interest paid under section 214(a) (2) of the 1921 Act. With this contention we can not agree. The bonds were the obligation of the Levee Dis”
1 later decision quote this exact passage
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.