Campbell v. Fields’s Empirical Analysis
229 F.2d 197 · 1956
Citation profile
20 federal appellate · 1 state decisions
How this case has been cited
Cited by 33 later decisions — most recently March 2019 · most notably Southern Natural Gas Co. v. United States (1969), Patterson v. Thomas (1961)
20 federal appellate · 1 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
Relies on Deputy v. du Pont · Higgins v. Commissioner · Kornhauser v. United States · Von Baumbach v. Sargent Land Co. · Railroad Commission of Texas v. Rowan & Nichols Oil 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Here the controverted deductions were not made for acquiring property or defending title to property, nor for the purpose of converting one kind of property into some different kind of property. Here the expenses were incurred in order that the taxpayers might realize and enjoy the income from the property.””
2 later decisions quote this exact passage · from the majority“| 162. Trade or business expenses (a) In general.—There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, * * * ****** (b) Charitable contributions and gifts excepted.—No deduction shall be allowed under subsection (a) for any contribution or gift which would be allowable as a deduction under section 170 were it not for the percentage limitations [the dollar limitations], or the requirements as to the time of payment, set forth in such section. ****** (26 U.S.C. 1958 ed., § 162.) § 170. Charitable, etc., contributions and gifts (a) Allowance of deduction.— (1) General rule.—There shall be allowed as a deduction any charitable contribution (as defined in subsection (c)) payment of which is made within the taxable year. A charitable contribution shall be allowable as a deduction only if verified under regulations prescribed by the Secretary or his delegate. ****** (b) Limitations.— ****** (2) Corporations.—In case of a corporation, the total deductions under subsection (a) for any taxable year shall not exceed 5 percent of the taxpayer’s taxable income. * * * ****** (c) Charitable contribution de fined.—For purposes of this section, the term “charitable contribution” means a contribution or gift to or for the use of— (1) A state, a Territory, a possession of the United States, or any political subdivision of any of the foregoing, or the United States or the District of Columbia,”
1 later decision quote this exact passage · from the majority“Expenditures that create or add to assets in a permanent rather than transitory way, are generally considered capital expenditures. Those that are made as a necessary incident to the current production of income or keeping in repair of a physical property, are in the nature of expenses and are thus deductible.”
1 later decision quote this exact passage · from the majoritye.g. Usry v. Price
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.