Robert M. Diggs and Clara C. Diggs v. Commissioner of Internal Revenue’s Empirical Analysis
1960
Citation profile
21 federal appellate · 1 district ·
How this case has been cited
Cited by 42 later decisions (1 by the Supreme Court) — most recently September 2015 · most notably Knetsch v. United States (1960), Grodt & McKay Realty, Inc. v. Commissioner (1981)
21 federal appellate · 1 district ·
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. § 23 · 26 U.S.C. § 264
Relies on Gregory v. Helvering · Automobile Club of Mich. v. Commissioner · Helvering v. New York Trust Co. · Wisconsin v. Illinois · Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal Revenue
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * The opinion in Gregory v. Helvering permits proper tax avoidance. * * * [A]t the least Gregory v. Helvering requires that a taxpayer carry an unusually heavy burden when he attempts to demonstrate that Congress intended to give favorable tax treatment to the kind of transaction that would never occnr absent the motive of tax avoidance. * * * Id. at 329-80.”
2 later decisions quote this exact passage · from the majority““The legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted. * * * But the question for determination is whether what was done, apart from the tax motive, was the thing which the statute intended.””
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.