Dittmar v. Commissioner’s Empirical Analysis
1955
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 16 later decisions — most recently October 2018
3 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
Relies on John Kelley Co. v. Commissioner · Gooding Amusement Co. v. Commissioner · Schnitzer v. Commissioner · Matthiessen v. Commissioner · United States v. Plumb
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The first question we must decide is whether petitioner's advances to Lone Star [a subsidiary corporation wholly owned by taxpayer-petitioner] were loans or were capital contributions. Petitioner contends, and has the burden of proving, that the advances were loans and that he is entitled to a full deduction, as a business bad debt, * * * of the unpaid balance thereof. * * *. 12”
1 later decision quote this exact passage“* * * we cannot avoid the inference that petitioner never did intend to enforce payment of the advances or assert the rights of a genuine creditor and that, in fact, his `state of mind * * * [with respect to the advances] was akin to that of the ordinary shareholder, who understands that his investment is subject to the risks of the venture and the prior claims of creditors.' 17”
1 later decision quote this exact passage · from the majority““(2) Securities becoming worthless. If any securities (as defined in paragraph (3) of this subsection} become worthless during the taxable year and are capital assets, the loss resulting therefrom shall, for the purposes of this chapter, be considered as a loss from the sale or exchange, on the last day of such taxable year, of capital assets.””
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.