Giblin v. Commissioner’s Empirical Analysis
1955
Citation profile
48 federal appellate · 1 district ·
How this case has been cited
Cited by 100 later decisions (1 by the Supreme Court) — most recently August 2010 · most notably Whipple v. Commissioner (1963), Hirsch v. Commissioner (1963)
48 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. § 23
Relies on Higgins v. Commissioner · Rowan v. United States · Maloney v. Spencer · Campbell 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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) General rule. Debts which become worthless within the taxable year; or (in the discretion of the Commissioner) a reasonable addition to a reserve for bad debts; and when satisfied that a debt is recoverable only in part, the Commissioner may allow such debt, in an amount not in excess of the part charged off within the taxable year, as a deduction. * * * * * * * *”
8 later decisions quote this exact passage · from the majority““Taxpayer did not seek to show that he was engaged in the business of making loans. Neither did he seek to have the Tax Court ‘pierce the corporate veil’ and find that he was engaged in the restaurant business or in any of the other businesses which he had promoted and dealt with during the preceding twenty years. What he did seek to prove was that he was regularly engaged in the business of seeking out business opportunities, promoting, organizing and financing them, contributing to them substantially 50% of his time and energy and then disposing of them either at a profit or loss if if #”
6 later decisions quote this exact passage · from the majority“requires an examination of the facts in each case.”
5 later decisions 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.