Helvering v. Gowran’s Empirical Analysis
302 U.S. 238 · 1937
Citation profile
1,141 federal appellate · 33 district · 140 state decisions
How this case has been cited
Cited by 1,833 later decisions (46 by the Supreme Court) — most recently July 2022 · most notably Securities and Exchange Commission v. Chenery Corporation (1943), Brown v. Allen (1953)
1,141 federal appellate · 33 district · 140 state decisions — followed in 11 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
reviewedGowran v. Commissioner of Internal Revenue (from Seventh Circuit Court of Appeals)
Relationships
Relies on Gregory v. Helvering · Eisner v. Macomber · Burnet v. Harmel · Langnes v. Green
Cited together with Securities and Exchange Commission v. Chenery Corporation · Riley Inv Co v. Commissioner of Internal Revenue · Hormel v. Helvering · United States v. United States Gypsum Co. · Erie Co v. Tompkins
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 1,833 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the review of judicial proceedings the rule is settled that if the decision below is correct, it must be affirmed, although the lower court relied upon a wrong ground or gave a wrong reason.”
55 later decisions quote this exact passage · from the majority““any distribution made by a corporation to its shareholders, whether in money or in other property, (1) out of its earnings or profits accumulated after February 28, 1913, or (2) out of the earnings or profits of the taxable year * *”
7 later decisions quote this exact passage · from the majority““If the Commissioner was right in his determination, the Board properly affirmed it, even if the reasons which he had assigned were wrong. And, likewise, if the Commissioner’s determination was right, the Board’s af-firmance of it should have been sustained by the Court of Appeals, even if the Board gave a wrong reason for its action.””
3 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.