Allen v. Selig’s Empirical Analysis
200 F.2d 487 · 1952
Citation profile
27 federal appellate ·
How this case has been cited
Cited by 47 later decisions — most recently July 1984 · most notably Industrial Aggregate Co. v. United States (1960), Manufacturers Hanover Trust Co. v. United States (1963)
27 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 Bingham's Trust v. Commissioner of Internal Revenue · Lykes v. United States · Jones' Estate 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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““So finding, he concluded, with eminent correctness, that the equitable action, instituted by plaintiff to declare her ownership and compel the executors to execute a deed in accordance therewith, was not a suit to obtain or defend title, but was essentially conservatory in its nature, one to conserve income producing property which she already owned, and to free her management from unwarranted fetters.” Allen v. Selig, 5 Cir., 1952, 200 F.2d 487 , 488.”
2 later decisions quote this exact passage“The Superior Court action instituted by the Plaintiff did involve the transfer of legal title to her. This, however, was incidental as legal title would have ultimately passed to her by inheritance. Title, even though equitable, was and had been in the Plaintiff. The real purpose of her action was to prevent the laying waste of her property by assessment of wrongful estate taxes and administration expenses against it. * * *”
1 later decision quote this exact passage“(a) Expenses.— ******* (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.”
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.