Garrett v. Crenshaw’s Empirical Analysis
196 F.2d 185 · 1952
Citation profile
35 federal appellate ·
How this case has been cited
Cited by 56 later decisions — most recently December 1982 · most notably Industrial Aggregate Co. v. United States (1960), Lewis v. Commissioner (1958)
35 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 Kornhauser v. United States · Hochschild v. Commissioner · Rassenfoss v. Commissioner · Bowers v. Lumpkin
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““§ 23. Deductions from gross income. In computing net income there shall be allowed as deductions: “(a) Expenses. “(1) Trade or business expenses. “(A) In general. All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually ren— dered; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or business; and rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity. $ $ $ $ “(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.””
3 later decisions quote this exact passage“Expenditures incurred in defending or perfecting title to property, in recovering property (other than investment property and amounts of income which, if and when recovered, must be included in income), or in developing or improving property, constitute a part of the cost of the property and are not deductible expenses. Attorneys’ fees paid in a suit to quiet title to lands are not deductible; but if the suit is also to collect accrued, rents thereon, that portion of such fees is deductible which is properly allocable to the services rendered in collecting such rents. * * * [Emphasis supplied.]”
1 later decision quote this exact passage“* * * defense and perfection of taxpayer's title to property in which, prior to the litigation, he held only an equitable interest based upon a parol trust.”
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.