Texas Ry Co v. United States’s Empirical Analysis
286 U.S. 285 · 1932
Citation profile
28 federal appellate · 9 district ·
How this case has been cited
Cited by 79 later decisions (20 by the Supreme Court) — most recently July 2020 · most notably Continental Tie & Lumber Co. v. United States (1932), Helvering v. Midland Mutual Life Insurance (1937)
28 federal appellate · 9 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
Relies on Lewis v. Reynolds · Edwards v. Cuba Railroad · United States v. Guaranty Trust Co.
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 79 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If the fruits of the employment of a road’s capital and labor should fall below a fixed minimum, then the government agreed to make up the deficiency, and, if the income were to exceed that minimum, the carrier bound itself to pay the excess into the federal treasury. In the latter event, the carrier unquestionably would have been obligated to pay income tax measured by actual earnings; in the former, it ought not to be in a better position than if it has earned the specified minimum. Clearly, then, the amount paid to bring the yield from operation up to the required minimum was as much income from operation as were the railroad’s receipts from fares and charges.”
2 later decisions quote this exact passage · from the majority“The sums received under the act were not subsidies or gifts — that is, contributions to the capital of the railroads — and this fact distinguishes cases such as Edwards. ... Here the [sums] were to be measured by a deficiency in operating income, and might be used for the payment of dividends, of operating expenses, of capital charges, or for any other purpose within the corporate authority, just as any other operating revenue might be applied.”
1 later decision quote this exact passage · from the majority“In a proper sense these payments constituted income to the carrier not exempt from taxation under the Sixteenth Amendment or the Revenue Act of 1918.”
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.