Evans v. Dudley’s Empirical Analysis
1960
Citation profile
8 federal appellate ·
Relationships
Applies 26 U.S.C. § 171
Relies on Gregory v. Helvering · Lewyt Corporation v. Commissioner of Internal Revenue · Carl E. Weller and Emily I. Weller v. Commissioner of Internal Revenue, W. Stuart Emmons v. Commissioner of Internal Revenue · Commissioner v. Korell · Fabreeka Products Co. 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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the amount payable on maturity or on earlier call date”
3 later decisions quote this exact passage“The government inferentially is suggesting that this court is empowered to legislate on what appears to be a loophole in the law permitting a double deduction. Such power rests with Congress and not the courts____ General equitable considerations do not control the measure of deductions or tax benefits. It is as applicable to the government as the taxpayer. Congress may be strict or lavish in its allowance of deductions or tax benefits. The formula it writes may be arbitrary and harsh in its applications. But, where the benefit claimed by the taxpayer is fairly within the statutory language and the construction sought is in harmony with the statute as an organic whole, the benefits will not be withheld from the taxpayer though they represent an unexpected windfall. It is clear that a court cannot impose equitable considerations in controlling the measure of deductions or tax benefits. The Court is not empowered to legislate or impose restrictive conditions which are not present in the law. While an intention to allow one expenditure to be deducted twice under a single statutory provision will not be imputed to Congress, a double tax benefit is obtainable from a single cash outlay under different sections of the law unless Con gress has indicated that one or the other shall be inapplicable.”
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.