Curry v. Commissioner’s Empirical Analysis

Citation profile

8 federal appellate · 1 state decisions

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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““But it seems manifest to us that when a taxpayer knows the worthlessness of a debt in a certain year and yet chooses to indulge in hopes that something may still be realized from a claim that at the time has neither collectibility nor market value, lie ought not to be allowed to delay taking his deduction until all his hopes or illusions are completely dispelled, for it had ceased to have a commercial value. While the test of ascertainment is a subjective one, and the taxpayer will not lose his right to deduct a worthless debt through a mere error of judgment, proof that in a particular year the facts known to Mm indidated the worthlessness of the debt and that it was then actually worthless seems to justify an inference that he then ascertained it to be worthless.””

   1 later decision quote this exact passage · from the majority
   e.g. Paramount Liquor Co. v. Commissioner

2. ““§ 23. Deductions from Gross Income. “In computing net income there shall be allowed as deductions: 4 4 4 4 4 4 4 “(k) Bad Debts. Debts ascertained to be worthless and charged off within the taxable year (or, in the discretion of the Commissioner, a reasonable addition to a reserve for bad debts); and when satisfied that a debt is recoverable only in part, the Commissioner may allow such debt, in an amount not in excess of the part charged off within the taxable year, as a deduction.” 26 U.S.C.A. Int.Rev. Acts, page 828.”

   1 later decision quote this exact passage · from the majority
   e.g. Mayer Tank Mfg. Co. v. Commissioner