Dorzback v. Collison’s Empirical Analysis
195 F.2d 69 · 1952
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 24 later decisions — most recently November 2018
7 federal appellate ·
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. § 23
Relies on Deputy v. du Pont · Helvering v. Clifford · Commissioner v. Tower · Old Colony Co v. Commissioner of Internal Revenue · Commissioner v. O. P. P. Holding Corp.
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * There is no requirement in Section 23(b) that deductible interest be ordinary and necessary or even that it be reasonable. 4 Mertens, Law of Federal Income Taxation, § 26.01. Hence the phrase ‘All interest paid’ contained in that section must be taken in its plain and literal meaning to include whatever sums the taxpayer has actually had to pay for the use of money which he has borrowed. * * *" ( 195 F.2d at 72, 73 )”
1 later decision quote this exact passage · from the majority“The phrase 'in lieu of' means 'instead of.' "). By substituting Special Condition 6 for Special Condition C, the Corps effectively and unlawfully "reject[ed]”
1 later decision quote this exact passage · from the majority“all interest paid or accrued within the taxable year on indebtedness”
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.