West Seattle National Bank v. Commissioner’s Empirical Analysis
288 F.2d 47 · 1961
Citation profile
37 federal appellate · 2 district ·
How this case has been cited
Cited by 73 later decisions (1 by the Supreme Court) — most recently September 2013 · most notably Hillsboro National Bank v. Commissioner (1983), Putoma Corp. v. Commissioner (1976)
37 federal appellate · 2 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 Commissioner of Internal Revenue v. Court Holding Co · United States v. Cumberland Public Service Co. · National Bank of Commerce v. Commissioner of Internal Revenue · Merchants Nat. Bank of Mobile v. Commissioner
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 73 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Nor does the fact that the bad debt reserve is generally regarded as a valuation reserve affect the result. While the book value established thereby has an accounting significance, it is still based upon an expectation that loss of value will occur and not upon the fact that such loss has already occurred. It is a prediction of value and not a statement of present fact. Recovery of a debt which has been written off is not then a realization of a gain in asset value. It simply demonstrates that the value prediction was faulty and did not conform to the fact.””
3 later decisions quote this exact passage · from the majority“There it was said that to the extent of deductions taken, a debt loses its nature as capital and takes on the character of the untaxed income which the deduction represents. * * *”
1 later decision quote this exact passage · from the majority“* * * increment realized in this area over and beyond adjusted basis does not then represent any gain in capital or asset value.”
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.