26 U.S.C. § 261
Section 261 · General rule for disallowance of deductions
Amended 1 time on record
Applied in 26 court decisions — leading case Commissioner of Internal Revenue v. Idaho Power Company (1974)
Most recently applied in Dept. of Rev. v. Wakefield (February 2022)
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
In computing taxable income no deduction shall in any case be allowed in respect of the items specified in this part.