Walter I. Dodd and Amelia Lee Dodd v. Commissioner of Internal Revenue’s Empirical Analysis
1962
Citation profile
10 federal appellate · 2 district ·
How this case has been cited
Cited by 34 later decisions — most recently September 2010 · most notably Betson v. Commissioner (1986), Lohrke v. Commissioner (1967)
10 federal appellate · 2 district ·
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
Applies 26 U.S.C. § 162
Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · Deputy v. du Pont · Moline Properties, Inc. v. Commissioner · Interstate Transit Lines 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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““If the taxpayer * * * were permitted to deduct, as his personal business expenses, the expenses which were clearly those of the corporation and incurred by reason of its operation, the principle of tax law recognizing the corporate entity would be seriously violated.” 5”
3 later decisions quote this exact passage · from the majority“It is unreasonable to conclude that * * * a prudent creditor would continue to make unsecured loans to a debtor with expectation of repayment.”
2 later decisions quote this exact passage · from the majority“to the contention that his own individual business and that of the corporation were so intertwined as to be virtually one, and the expenses of the corporation (to the extent of the advances not repaid) presumably deductible by the corporation itself, were also deductible expenses of the taxpayer's separate business.”
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.