Helvering v. Stormfeltz’s Empirical Analysis
142 F.2d 982 · 1944
Citation profile
24 federal appellate · 2 district ·
How this case has been cited
Cited by 52 later decisions — most recently April 2005 · most notably Hochschild v. Commissioner (1947), Industrial Aggregate Co. v. United States (1960)
24 federal appellate · 2 district ·
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 Dobson v. Commissioner · Higgins v. Commissioner · Security Flour Mills Co. v. Commissioner · United States v. Pyne · City Bank Farmers Trust Co. v. Helvering
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 52 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) Dispenses ***** “(2) Non-trade or non-business expenses. In the case of an individual, all the ordinary and necessary expenses paid or incurred during the taxable year for the production or collection of income, or for the management, conservation, or maintenance of property held for the production of income. $ * * * * “(e) Losses by individuals. In the case of an individual, losses sustained during the taxable year and not compensated for by insurance or otherwise— “(1) if incurred in trade or business; or “(2) if incurred in any transaction entered into for profit, though not connected with the trade or business; or “ (3) of property not connected with the trade or business, if the loss arises from fires, storms, shipwreck, or other casualty, or from theft. No loss shall be allowed as a deduction under this paragraph if at the time of the filing of the return such loss has been claimed as a deduction for estate tax purposes in the estate tax return. * * *””
5 later decisions quote this exact passage · from the majority“* * * Expenses for management, conservation or maintenance imparts the idea of utilization and preservation of specific property owned and used by the taxpayer.”
2 later decisions quote this exact passage · from the majority“* * * Insofar as the recovery consisted of interest, it was income and the expense of its collection was clearly deductible. * * * Respondent was entitled to a deduction of that portion of the expenses properly allocable to the recovery of interest, but was not entitled to a deduction for that part of the expenses properly allocable to the recovery of capital.”
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.