Cowden v. Commissioner’s Empirical Analysis
1961
Citation profile
22 federal appellate ·
How this case has been cited
Cited by 41 later decisions — most recently December 2019 · most notably In the Matter of Charles A. Steen, Debtor. Dick Dimond, Trustee v. United States (1975), Warren Jones Co. v. Commissioner (1975)
22 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
Relies on Gregory v. Helvering · Burnet v. Harmel · Knetsch v. United States · Palmer v. Bender · United States v. Phellis
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“if the promise to pay of a solvent obligor is unconditional and assignable, not subject to set-offs, and is of a kind that is frequently transferred to lenders or investors at a discount not substantially greater than the generally prevailing premium for the use of money, such promise is the equivalent of cash”
3 later decisions quote this exact passage · from the majority““A promissory note, negotiable in form, is not necessarily the equivalent of cash. Such an instrument may have been issued by a maker of doubtful solvency * * * [and thereby it might be] denied a ready acceptance in the market place. * * * [But where] a promise to pay of a solvent obligor is unconditional and * * * frequently transferred * * * such promise is the equivalent of cash * * * . [Fn. ref. omitted.]””
1 later decision quote this exact passage · from the majority“negotiability is not the test of taxability in an equivalent of cash case”
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.