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← 13 TC 897 - Whitney v. Commissioner

Whitney v. Commissioner’s Empirical Analysis

1949

Citation profile

13
cited by 13 later decisions
March 2011
most recently cited

1 federal appellate ·

How this case has been cited

Cited by 13 later decisions — most recently March 2011

1 federal appellate ·

6019491950196019701980199020002010decided

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 Boehm v. Commissioner · Burnet v. Houston · Larson v. Sylvester · Mason v. Pomeroy · Peyton 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “losses of property " (emphasis added) that arise from casualty. In Whitney v. Commissioner , 13 T.C. 897 , 899 (1949) , this Court observed that "the losses allowable under section 23(e)(3) [a predecessor to section 165 ] are specifically limited to losses of property arising from casualty, and damages paid for injuries and wrongful death are plainly without the provisions of the statute.”
    1 later decision quote this exact passage
  2. ““Losses, to be deductible under the revenue laws, must be actual, realized losses, and in any case where there is a reasonable ground for reimbursement the taxpayer must seek his redress and may not secure a loss deduction until he establishes that no recovery may be had. * * * ””
    1 later decision quote this exact passage
  3. “It is a startling proposition that a taxpayer may, for reasons of his own, decline to enforce a valid claim against a responsible concern and then assert that he has sustained a business loss which the Government should share.”
    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.