Helvering v. Mountain Producers Corp.’s Empirical Analysis
303 U.S. 376 · 1938
Citation profile
130 federal appellate · 13 district · 82 state decisions
How this case has been cited
Cited by 370 later decisions (72 by the Supreme Court) — most recently February 2024 · most notably National League of Cities v. Usery (1976), Smith v. Allwright (1944)
130 federal appellate · 13 district · 82 state decisions — followed in 19 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
reviewedthe decision below (from Tenth Circuit Court of Appeals)
Relationships
Relies on M'Culloch v. State of Maryland · Osborn v. President Directors and Company of the Bank of the United States · James v. Dravo Contracting Co. · Sproles v. Binford · Metcalf & Eddy v. Mitchell
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 370 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“These decisions in a variety of applications enforce what we deem to be the controlling view — that immunity from non-discriminatory taxation sought by a private person for his property or gains because he is engaged in operations under a government contract or lease cannot be supported by merely theoretical conceptions of interference with the functions of government. Regard must be had to substance and direct effects. And, where it merely appears that one operating under a government contract or lease is subjected to a tax with respect to his profits on the same basis as others who are engaged in similar businesses, there is no sufficient ground for holding that the effect upon the government is other than indirect and remote. * * *”
8 later decisions quote this exact passage · from the majority““The power to tax should not be crippled ‘by extending the constitutional exemption from taxation to those subjects which fall within the general application of nondis criminatory laws, and where no direct burden is laid upon the governmental instrumentality and there is only remote, if any, influence upon the exercise of the functions of government’. Will cuts v. Bunn, 282 U.S. 216, 225 , 75 L. Ed. 304, 306 , 51 S. Ct. 125 , 71 A.L.R. 1260 , and illustrations there cited.””
3 later decisions quote this exact passage · from the majority““But to appraise the actual extent of depletion on the particular facts in relation to each taxpayer would give rise to problems of considerable perplexity and would create administrative difficulties which it was intended to overcome by laying down a simple rule which could be easily applied. To this end, the taxpayer was permitted to deduct a specified percentage of his gross income from the property. See United States v. Dakota-Montana Oil Co., 288 U.S. 459 , 461, 53 S.Ct. 435 , 436, 77 L.Ed. 893 . Congress was free to give such an arbitrary allowance as the deduction was an act of grace. In answer to the contention that the provision may produce ‘unjust and unequal results,’ we have remarked that this is likely to be so ‘wherever a rule of thumb is applied without a detailed examination of the facts affecting each taxpayer.’ Helvering v. Twin Bell [Oil] Syndicate, 293 U.S. 312 , 321, 55 S.Ct. 174 , 178, 79 L.Ed. 383 . “The rule being of this sort for obvious purposes of administrative convenience, we must apply it in the simple manner it contemplates.””
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.