United States v. Simon’s Empirical Analysis
281 F.2d 520 · 1960
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 22 later decisions — most recently March 2003
7 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
Applies 26 U.S.C. § 23
Relies on Welch v. Helvering · Commissioner v. Sunnen · New Colonial Ice Co. v. Helvering · Cromwell v. County of Sac · Yates 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.
““We fail to see any business purpose in making the modification agreement retroactive so as to provide for refunding of rentals already paid in a prior tax year. The sole reason, in our judgment, was to obtain a tax advantage either for the corporation, or taxpayers or both. This is not sufficient to justify the deduction claimed as payment of an ‘obligation’ within the sense of claim of right. We agree with the decisions previously discussed which hold that no ‘obligation’ arises from a voluntary agreement to repay monies which the taxpayer would otherwise have an absolute and unconditional right to retain.” (p. 526)”
3 later decisions 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.