Schafer v. Helvering’s Empirical Analysis
299 U.S. 171 · 1936
Citation profile
40 federal appellate · 6 district · 2 state decisions
How this case has been cited
Cited by 108 later decisions (7 by the Supreme Court) — most recently February 2007 · most notably Automobile Club of Mich. v. Commissioner (1957), Kemon v. Commissioner (1951)
40 federal appellate · 6 district · 2 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
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Seeley v. Helvering · Commissioner v. Stevens · Hammitt v. Commissioner of Internal Revenue · Vaughan 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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"§ 1.471-5 Inventories by dealers in securities ****** “ * * * For the purposes of this section, a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom. * * * Taxpayers who buy and sell or hold securities for investment or speculation, irrespective of whether such buying or selling constitutes the carrying on of a trade or business * * * are not dealers in securities within the meaning of this section.””
2 later decisions quote this exact passage · from the majority“(a) At cost, (b) At cost or market, whichever is lower, or (c) At market value,”
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.