Smith v. Commissioner’s Empirical Analysis
1951
Citation profile
6 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 46 later decisions — most recently May 2000 · most notably Cotnam v. Commissioner (1959), Commissioner v. Smith (1953)
6 federal appellate · 1 district · 2 state decisions
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 Higgins v. Commissioner · Campbell v. Commissioner · Sage v. Commissioner · Commissioner v. People's-Pittsburgh Trust Co. · Hutchings v. Burnet
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“is substantially the same as that which is made for the purpose of ascertaining whether a loss from the type of transaction covered by section 23(e) is `incurred in trade or business' under paragraph (1) of that section.”
2 later decisions quote this exact passage · from the dissent““(a) *' * * The question whether the debt is one the losa from the worthlessness of which is incurred in the taxpayer’s trade or business is a question of fact in each particular case. * * * “(b) The character of the debt for this purpose * * * is to be determined rather by the relation which the loss resulting from the debt’s becoming worthless bears to the trade or business of the taxpayer. If that relation is a proximate one in the conduct of the trade or business in which the taxpayer is engaged at the time the debt becomes worthless, the debt is not a non-business debt for the purposes of this section.””
1 later decision quote this exact passage · from the dissent
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.