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← 279 F.2d 445 - Vitter v. United States

Vitter v. United States’s Empirical Analysis

279 F.2d 445 · 1960

Citation profile

22
cited by 22 later decisions
1
states following
March 1980
most recently cited

16 federal appellate · 1 district · 1 state decisions

How this case has been cited

Cited by 22 later decisions — most recently March 1980

16 federal appellate · 1 district · 1 state decisions

190196019701980decided

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. § 4241

Relies on Commissioner of Internal Revenue v. Flowers · Boehm v. Commissioner · Helvering v. Winmill · Helvering v. R. J. Reynolds Tobacco Co. · White v. United States

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

  1. ““(b) Initiation fees. — As used in this part the term ‘initiation fees” includes any payment, contribution, ■or loan, required as a condition precedent to membership, whether or not any such payment, contribution, ■or loan is evidenced by a certificate ■of interest or indebtedness or share of stock, and irrespective of the person or organization to whom paid, contributed, or loaned.” (Emphasis supplied.) 26 U.S.C.A. § 4242 (b).”
    3 later decisions quote this exact passage · from the majority
  2. “When a Treasury Regulation interprets a section of the Code and the Regulation remains in effect and unchanged for a long period of time, re-enactment of the statute without change is presumed to show congressional approval of the Regulation which thereby acquires the force and effect of law * * * [numerous cases cited].”
    2 later decisions quote this exact passage · from the majority
  3. ““But this is an artificial cutting up of a single statute into several unrelated parts, not a reading of it together as a whole. The second part, § 4242, is not separate. Indeed, its topic head as “Definitions” shows a congressional purpose to read all stated in § 4242 as though it were physically written into § 4241. As reconstructed its meaning is substantially this. There is imposed a 20% tax on any amount paid, contributed or loaned as a condition precedent to membership in a club irrespective of the person or organization to whom such payment, contribution or loan is made and whether that which is received for such payment, contribu tion or loan is evidenced by a certificate of interest or indebtedness or share of stock.””
    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.