Hofferbert, Collector of Internal Revenue v. Anderson Oldsmobile, Inc’s Empirical Analysis
197 F.2d 504 · 1952
Citation profile
11 federal appellate · 1 district ·
How this case has been cited
Cited by 25 later decisions — most recently November 2018 · most notably Reading v. Commissioner (1978), Fischler v. McCarthy (1954)
11 federal appellate · 1 district ·
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. § 22 · 26 U.S.C. § 23
Relies on Eisner v. Macomber · United States v. Sullivan · Rutkin v. United States · Doyle v. Mitchell Bros. · Burnet v. Logan
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) General Definition — ‘Gross Income’ includes gains, profits, and income derived from salaries, wages, or compensation for personal service, of whatever hind and in whatever form paid, or from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived from any source whatever * * * ” 26 U.S.C. 1946 ed. § 22. Treasury Regulations 111, promulgated under the Internal Revenue Code. “Sec. 29.22 (a)-5. Gross Income From Business. In the case of a manufacturing, merchandising, or mining business, ‘gross income’ means the total sales, less the cost of goods sold, plus any income from investment and from incidental or outside operations or sources. In determining the gross income subtractions should not be made for depreciation, depletion, selling expenses, or losses, or for items not ordinarily used in computing the cost of goods sold. * * * ””
2 later decisions quote this exact passage · from the majority“as to manufactured goods, the distinction [between costs and deductions ] is often technical and economically obscure.”
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.