Brown v. Helvering’s Empirical Analysis
291 U.S. 193 · 1934
Citation profile
203 federal appellate · 9 district · 4 state decisions
How this case has been cited
Cited by 513 later decisions (23 by the Supreme Court) — most recently October 2020 · most notably Speiser v. Randall (1958), Automobile Club of Mich. v. Commissioner (1957)
203 federal appellate · 9 district · 4 state decisions
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.
Appellate journey
reviewedBrown v. Commissioner (from Ninth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 955
Relies on United States v. Anderson · North American Oil Consolidated v. Burnet · Lucas v. American Code Co. · Maryland Casualty Co. v. United States · Weiss v. Wiener
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 513 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a liability does not accrue as long as it remains contingent.”
4 later decisions quote this exact passage · from the majority“[i]t is not the province of the court to weigh and determine the relative merits of systems of accounting.”
3 later decisions quote this exact passage · from the majority“The overriding commissions were gross income of the year in which they were receivable. As to each such commission there arose the obligation — a contingent liability — to return a proportionate part in case of cancellation. But the mere fact that some portion of it might have to be refunded in some future year in the event of cancellation or reinsurance did not affect its quality as income. [Id. at 199, 54 S.Ct. at 359.]”
2 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.