← 200 F.2d 846 - Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, Inc

Earle, Collector of Internal Revenue v. W. J. Jones & Son, Inc. United States v. W. J. Jones & Son, Inc’s Empirical Analysis

200 F.2d 846 · 1952

Citation profile

cited by 60 later decisions

states following

April 2006

most recently cited

31 federal appellate · 3 district · 2 state decisions

How this case has been cited

Cited by 60 later decisions — most recently April 2006 · most notably Gooding Amusement Company, Incorporated v. Commissioner of Internal Revenue, F. E. Gooding v. Commissioner of Internal Revenue, Anna Elizabeth Gooding v. Commissioner of Internal Revenue, F. E. Gooding and Elizabeth Gooding v. Commissioner of Internal Revenue (1956), Jack Daniel Distillery v. United States (1967)

31 federal appellate · 3 district · 2 state decisions

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 · 28 U.S.C. § 1346 (Federal Tort Claims Act)

Relies on United States v. United States Gypsum Co. · United States v. Yellow Cab Co. · John Kelley Co. v. Commissioner · Orvis v. Higgins · United States v. United States Gypsum Co.

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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“One who makes a loan to a corporation also takes a risk, and while he may receive evidence of an obligation, payable in any event, often such obligation is never paid. . . . `All unsecured loans involve more or less risk.'”
3 later decisions quote this exact passage · from the majority
e.g. Brighton Recreations, Inc. v. Commissioner · Byerlite Corporation v. Parker C. Williams, District Director of Internal Revenue, Eighteenth District of Ohio
“Findings as to the design, motive and intent with which men act depend peculiarly upon the credit given to witnesses by those who see and hear them.”
1 later decision quote this exact passage · from the majority
e.g. Gooding Amusement Company, Incorporated v. Commissioner of Internal Revenue, F. E. Gooding v. Commissioner of Internal Revenue, Anna Elizabeth Gooding v. Commissioner of Internal Revenue, F. E. Gooding and Elizabeth Gooding v. Commissioner of Internal Revenue
“was conservatively estimated to be at least $50,000 in excess of its purchase price”
1 later decision quote this exact passage · from the majority
e.g. Mason-Dixon Sand & Gravel Co. v. Commissioner

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.