United States v. Supplee-Biddle Hardware Co.’s Empirical Analysis

Citation profile

52 federal appellate · 6 district · 24 state decisions

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

1. ““Sec. 213. That for the purposes of tins title (except as otherwise provided in section 233) the term ‘gross income’— “(a) Includes gains, profits, and income derived from salaries, wages, or compensation for personal service (including in the ease of the President of the-United States, the judges of the Supreme and inferior courts of the United States, and all other officers and employees, whether elected or appointed, of the United States, Alaska, Hawaii, or any political subdivision thereof, or the District of Columbia, the compensation received as such), of whatever kind and in whatever form paid, or-from professions, vocations, trades, businesses, commerce, or sales, or dealings in property, whether real or personal, growing out of the ownership or use of or interest in such property; also from interest, rent, dividends, securities, or the transaction of any business carried on for gain or profit, or gains or profits and income derived from any source whatever. * * * “See. 201. (a) That the term ‘dividend’ when used in this title (except in paragraph [10] of subdivision [a] of section 234) means (1) any distribution made by a corporation, other than a personal service corporation, to its shareholders or members, whether in cash or in other property or in stock of the corporation, out of its earnings or profits accumulated since February 28,1913. * * * “(e) A dividend paid in stoek of the corporation shall be considered income to the amount of the earnings or profits dist”

   1 later decision quote this exact passage · from the majority
   e.g. Bigelow v. Bowers

2. ““We think the Treasury Department erred in assuming that Congress intended, by sections 233 and 213, to distinguish between individual beneficiaries and corporate beneficiaries in including the proceeds of life insurance policies as within gross income. We iliink the two sections have no such, purpose. Section 213 primarily applies only to the taxing of individuals. The union of proceeds of life insurance payable to individual beneficiaries and to the estate of the assured was thus intended to emphasize the exclusion from taxation in the hands of individuals of all such proceeds, and to leave no doubt of it. The meaning is the same as if the clause had read: ‘The proceeds of life insurance shall not be included in gross income, whether they are paid to individual beneficiaries or to the estate of the assured.’ When Congress came to deal with the gross income of corporations, it made, use of section 213 by reference, and grafted it on to 233. It is reasonable that the purpose of section 213 to exclude entirely the proceeds of life insurance policies from taxation in the ease of individuals should be given the same effect in adapting its application to corporations, and that such proceeds should be so excluded whether, by the direction of the insured they were to go to specially named beneficiaries, or were to inure to the estate of the insured. * * * “It is earnestly pressed upon us that proceeds of life insurance paid on the death of the insured are in fact capital, and canno”

   1 later decision quote this exact passage · from the majority
   e.g. Security Bank of Ponca City v. Oklahoma Tax Commission

3. ““The Supplee-Biddle Hardware Company sued the United 'States in the court of claims to recover $55,153.89, with interest, as taxes illegally assessed on the proceeds of two life insurance policies paid to it as the beneficiary on the death, in 1918, of the insured, Robert Biddle 2d. Biddle was elected president of the company in February, 1917. He was then thirty-seven years of age, in good health, and had for nearly twenty years held various offices in the Biddle Hardware Company, which had merged with the appellee company in. January, 1914. He was a man of ability, energy, and initiative, and was so regarded in the hardware trade. The returns from the company’s business under Biddle’s management had been much increased. At the instance of the board of directors and the expense of the company, he took out the two policies for $50,000 each. They were term policies for five years. The company intended thus to make secure its financial position, and to indemnify itself against losses to its earning power in the event of Biddle’s death.””

   1 later decision quote this exact passage · from the majority
   e.g. Security Bank of Ponca City v. Oklahoma Tax Commission