Smith v. Helvering’s Empirical Analysis
141 F.2d 529 · 1944
Citation profile
3 federal appellate ·
Relationships
Relies on Dobson v. Commissioner · Lucas v. American Code Co. · Rochester Telephone Corporation v. United States · Mahnich v. Southern Steamship Co. · United States v. S S White Dental Mfg Co of Pennsylvania
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The test proposed by the Board in the present case is a highly objective one which disregards what the taxpayer may think of his investment, how much of an optimist he may be, or what he may consider to be the possibilities of future successful operation, or of eventual recoupment. An examination of the cases persuades us that the subjective appraisal of the taxpayer is of much greater importance.””
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.