Evans v. Dudley’s Empirical Analysis

295 F.2d 713 · 1961

Citation profile

cited by 18 later decisions

cited 1 times by the Supreme Court

February 1969

most recently cited

11 federal appellate ·

Relationships

Applies 26 U.S.C. § 171

Relies on Gregory v. Helvering · Fabreeka Products Company v. Commissioner of Imternal Revenue, Sadie S. Friedman v. Commissioner of Internal Revenue, Jack L. Sherman v. Commissioner of Internal Revenue · Maysteel Products, Inc. v. Commissioner · United States Fidelity & Guaranty Co. v. Sweat

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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“3 As previously stated, Mr. Evans put up $118,000 of his own money. The amortizable bond deduction amounted to $170,500, resulting in a tax saving of $139,414. The gifts of $1,250,000 face amount bonds in 1954 resulted in an additional deduction of more than $87,000, and a gift of the remainder of the bonds in 1955 increased this figure to more than $100,000. Thus, taxpayer's total tax saving was close to $240,000. As the Government plaintively points out in its brief:”
1 later decision quote this exact passage · from the majority
e.g. Evans v. Dudley
“(B) with reference to the amount payable on maturity or on earlier call date (but in the case of bonds described in subsection (c) (1) (B) issued after January 22, 1951, and acquired after January 22, 1954, only if such earlier call date is a date more than 3 years after the date of such issue) * * *. * * * * *”
1 later decision quote this exact passage · from the majority
e.g. Evans v. Dudley
“Granting the government's proposition that these taxpayers have found a hole in the dike, we believe it one that calls for the application of the Congressional thumb, not the court's.”
1 later decision quote this exact passage · from the majority
e.g. Evans v. Dudley

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.