Helvering v. San Joaquin Fruit & Investment Co.’s Empirical Analysis
297 U.S. 496 · 1936
Citation profile
140 federal appellate · 12 district · 22 state decisions
How this case has been cited
Cited by 309 later decisions (17 by the Supreme Court) — most recently March 2017 · most notably Commissioner v. Smith (1945), Palmer v. Commissioner (1937)
140 federal appellate · 12 district · 22 state decisions — followed in 10 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
reviewedSan Joaquin Fruit & Investment Co. v. Commissioner (from Ninth Circuit Court of Appeals)
Relationships
Relies on Old Colony Co v. Commissioner of Internal Revenue · Willard v. Tayloe · Reinecke v. Smith · N. P. Severin Co. v. Young
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 309 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““We hold that the respondent acquired the property on November 30, 1916. The option itself was property, and doubtless was valuable. If it had been assignable, and the lessee had sold it at a profit, taxable gain would have resulted from the sale. But the option is admittedly not the same property as the land. So conceding, the respondent still insists that ownership of the option created an interest in the land. * * * “ * * * The capital asset, sale of which resulted in taxable gain, was the land. This was not an asset of the taxpayer prior to the exercise of the option. We think it clear that there was no combination of two capital assets, — the option and $200,-000 of cash, to form a new capital asset, the land, which was subsequently sold at a profit. * * * ””
10 later decisions quote this exact passage · from the majority““Sec. 113. Adjusted basis for determining gain or loss— “(a) Basis (unadjusted) of property. The basis of property shall be the cost of such property; except that— * * * * * * “(5) Property transmitted at death. If the property was acquired by bequest, devise, or inheritance, or by the decedent’s estate from the decedent, the basis shall be the fair mai-ket value of such property at the time of such acquisition. * * * ” 26 U.S.C.A.Int.Rev.Code, § 113(a) (5).”
1 later decision quote this exact passage · from the majoritye.g. Mack v. Commissioner“The basis for determining the gain or loss from the sale or other disposition of property acquired before March 1, 1913, shall be (A) the cost of such property ... or (B) the fair market value of such property as of March 1, 1913, whichever is greater.”
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.