Helvering v. O'Donnell’s Empirical Analysis
303 U.S. 370 · 1938
Citation profile
82 federal appellate · 3 district · 8 state decisions
How this case has been cited
Cited by 198 later decisions (26 by the Supreme Court) — most recently August 2010 · most notably Commissioner v. Southwest Exploration Co. (1956), Anderson v. Helvering (1940)
82 federal appellate · 3 district · 8 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
reviewedCommissioner of Internal Revenue v. O'Donnell (from Ninth Circuit Court of Appeals)
Relationships
Relies on Palmer v. Bender · Thomas v. Perkins · Helvering v. Bankline Oil Co. · Helvering v. Twin Bell Oil Syndicate
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 198 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The agreement to pay respondent one-third of the net profits derived from the development and operation of the properties was a personal covenant and did not purport to grant respondent an interest in the properties themselves. If there were no net profits, nothing would be payable to him. No trust was declared by which respondent could claim an equitable interest in the res.” Helvering v. O’Donnell, 1938, 303 U.S. 370 , 372, 58 S.Ct. 619 , 620, 82 L.Ed. 903 .”
2 later decisions quote this exact passage · from the majority“The question is whether respondent [taxpayer] had an interest, that is, a capital investment, in the oil and gas in place.”
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.