H. S. D. Co. v. Kavanagh’s Empirical Analysis
1951
Citation profile
38 federal appellate · 1 state decisions
How this case has been cited
Cited by 61 later decisions (2 by the Supreme Court) — most recently March 2002 · most notably Automobile Club of Mich. v. Commissioner (1957), Schuster v. Commissioner (1962)
38 federal appellate · 1 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
Applies 26 U.S.C. § 165 · 26 U.S.C. § 23
Relies on Vestal v. Commissioner of Internal Revenue · Woodworth v. Kales · Austin Co. v. Commissioner · Routzahn v. Brown
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under the foregoing circumstances, and especially because of the fact that the Commissioner was given the unusual power by Congress to approve the plan and trusts and did so at various times during the course of the years, with full knowledge of all details relating to them and their operations, we are of the opinion that the Commissioner, in this ease, was bound by the prior decisions of his predecessor that the plan complied with Section 165 (a) of the Internal Revenue Code, as amended, and that the trusts were exempt.”
1 later decision quote this exact passage · from the majority““In computing income for the purpose of determining income tax liability, contributions made by an employer to or under a stock bonus, pension or profit sharing plan are deductible in the year paid only if the trust created under such plan is exempt * * * or, if not so exempt, such contributions are deductible in the year paid only in the case of an employee whose beneficial interest in such contribution is non-forfeitable at the time made. * * * ” (Emphasis added.) p. 69.”
1 later decision quote this exact passage · from the majority“discriminatory in favor of employees who are officers”
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.