Heil Beauty Supplies, Inc. v. Commissioner’s Empirical Analysis
199 F.2d 193 · 1952
Citation profile
51 federal appellate · 3 district ·
How this case has been cited
Cited by 96 later decisions — most recently April 2022 · most notably Williams v. United States (1957), Silverman v. Commissioner (1976)
51 federal appellate · 3 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. § 23
Relies on Miles-Conley Co. v. Commissioner of Internal Revenue · Carmack Et Ux. v. Commissioner of Internal Revenue · Ingle Coal Corp. v. Commissioner of Internal Revenue · Twin City Tile & Marble 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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Such a (factual) determination is one that is entitled to be made on all the elements of the particular case.”
3 later decisions quote this exact passage · from the majority““Any payment arrangement between a corporation and a stockholder * * * is always subject to close scrutiny for income tax purposes, so that deduction will not be made, as purported salary, rental or the like, of that which is in the realities of the situation an actual distribution of profits.””
2 later decisions quote this exact passage · from the majority“The only issue presented is whether the salaries paid by petitioner to its president, vice-president, secretary-treasurer and one J. H. Collopy for services rendered in each of the calendar years involved were unreasonable and excessive and hence not deductible under Section 23(a) of the Internal Revenue Code [26 U.S.C.A. § 23]. * * * As already observed the only question before us at this time is whether this finding of the Tax Court is sustained by substantial evidence or whether it is clearly erroneous. The finding involved a pure question of fact.”
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.