Helvering v. Midland Mutual Life Insurance’s Empirical Analysis
300 U.S. 216 · 1937
Citation profile
87 federal appellate · 12 district · 4 state decisions
How this case has been cited
Cited by 273 later decisions (25 by the Supreme Court) — most recently June 1997 · most notably Helvering v. Clifford (1940), Commissioner of Internal Revenue v. Glenshaw Glass Company (1955)
87 federal appellate · 12 district · 4 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
reviewedMidland Mut. Life Ins. v. Commissioner of Internal Revenue (from Sixth Circuit Court of Appeals)
Relationships
Relies on Old Colony Trust Co. v. Commissioner · Louisville Joint Stock Land Bank v. Radford · Brushaber v. Union Pacific Railroad · Burnet v. Sanford & Brooks Co. · Old Colony Co v. Commissioner of Internal Revenue
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 273 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Bookkeeping entries, though in some circumstances of evidential value, are not determinative of tax liability.”
3 later decisions quote this exact passage · from the majority“* * * A mortgagee who, at foreclosure sale, acquires the property pursuant to a bid of the principal and accrued interest is, as purchaser and grantee, in a position no different from that of a stranger who acquires the property on a bid of like amount. It is true that the latter would be obliged to pay in cash the amount of his bid, while the formality of payment in cash is ordinarily dispensed with when the mortgagee acquires the property on his own bid. But the rights acquired qua purchaser are the same in either case; and, likewise, the legal effect upon the mortgage debt is the same. In each ease the debt, including the interest accrued, is paid. Where the stranger makes the purchase, the debt is discharged by a payment in cash; where the mortgagee purchases the property, the debt is discharged by means of a credit. * * *”
1 later decision quote this exact passage · from the majority“The company argues that taxation is a practical matter; that we should be governed by realities; that the reality is, that all the company got was the property; and that the property was worth less than the principal of the debt. The “reality” of the deal here involved would seem to be that respondent valued the protection of the higher redemption price as worth the discharge of the interest debt for which it might have obtained -a judgment. * * *”
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.