Helvering v. Morgan's, Inc.’s Empirical Analysis
293 U.S. 121 · 1934
Citation profile
135 federal appellate · 26 district · 85 state decisions
How this case has been cited
Cited by 422 later decisions (22 by the Supreme Court) — most recently August 2025 · most notably United States v. American Trucking Associations (1940), Phelps Dodge Corporation v. National Labor Relations Board (1941)
135 federal appellate · 26 district · 85 state decisions — followed in 17 states
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
reviewedMorgan's, Inc. v. Commissioner (from First Circuit Court of Appeals)
Relationships
Relies on Burnet v. Sanford & Brooks Co. · Helvering v. New York Trust Co. · Woolford Realty Co. v. Rose · General Box Corp. 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 422 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[t]he true meaning of a single section of a statute ..., however precise its language, cannot be ascertained if it be considered apart from related sections....'”
9 later decisions quote this exact passage · from the majoritye.g. Commissioner v. Engle · Resolution Trust Corporation, in Its Capacity as Receiver for City Savings, F.S.B., and the Resolution Trust Corporation, in Its Corporate Capacity v. Cityfed Financial Corp. Richard E. Simmons K. Michael Defreytas John W. Atherton, Jr. Gordon E. Allen Alfred J. Hedden Peter R. Kellogg John Kean, Jr. Gilbert G. Roessner George E. Mikula James P. McTernan Victor A. Pelson Marshall M. Criser. Resolution Trust Corporation, in Its Capacity as Receiver for City Savings, F.S.B. v. John W. Atherton, Jr. Gordon E. Allen Alfred J. Hedden Peter R. Kellogg John Kean, Jr. Gilbert G. Roessner James P. McTernan Resolution Trust Corporation, in Its Capacity as Receiver for City Savings, F.S.B., in No. 94-5307. Resolution Trust Corporation v. Alfred J. Schuster Thomas J. Lynam Martin R. Siegel Richard P. Pearlman Joan C. Moonan, Individually and as of the Estate of Robert J. Moonan Eugene J. Elias George Hurley William B. Brick James W. Dwyer Harry H. Jaeger John R. Hipple John C. Lauricella Louis A. Iatarola. Martin R. Siegel, and Joan C. Moonan, as of the Estate of Robert J. Moonan and Individually, in No. 94-5308“"* * * Section 200 * * * gives four [definitions] of which two use the verb `include' and two the verb `means.' That the draftsman used these words in a different sense seems clear. The natural distinction would be that where `means' is employed, the term and its definition are to be interchangeable equivalents, and that the verb `includes' imports a general class, some of whose particular instances are those specified in the definition. * * *." (Bracketed matter added.)”
7 later decisions quote this exact passage · from the majority““The revenue acts since the Sixteenth Amendment have consistently assessed income taxes on the basis of annual accounting periods, either the calendar year or the different fiscal year which the taxpayer may adopt. From the beginning these periods have been known as taxable years and the provisions of the taxing statutes have been drafted and enacted with primary reference to such normal accounting periods.””
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.