Haggar Co. v. Helvering’s Empirical Analysis
308 U.S. 389 · 1940
Citation profile
229 federal appellate · 29 district · 33 state decisions
How this case has been cited
Cited by 596 later decisions (26 by the Supreme Court) — most recently February 2025 · most notably Griffin v. Oceanic Contractors, Inc. (1982), Watt v. Alaska (1981)
229 federal appellate · 29 district · 33 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
reviewedHaggar Co. v. Commissioner (from Fifth Circuit Court of Appeals)
Relationships
Relies on Sorrells v. United States · Brewster v. Gage · Armstrong Paint & Varnish Works v. Nu-Enamel Corp. · Sanford's Estate v. Commissioner of Internal Revenue · Hassett v. Welch
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 596 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“All statutes must be construed in light of their purpose. A reading of them which would lead to absurd results is to be avoided when they can be given a reasonable application consistent with their words and with legislative purpose.”
14 later decisions quote this exact passage · from the majority““ ‘First return’ thus means a return for the first year in which the taxpayer exercises the privilege of fixing its capital stock value for tax purposes, and includes a timely amended return for that year. A timely amended return is as much a ‘first return’ for the purpose of fixing the capital stock value in contradistinction to returns for subsequent years, as is a single return filed by the taxpayer for the first tax year.” Haggar v. Helvering, supra, at 395 , 60 S.Ct. at 340 . “To construe ‘first return’ as meaning the first paper filed as a return, as distinguished from the paper containing a timely amendment, which, when filed is commonly known as the return for the year for which it is filed, is to [violate one] of the most elementary principles of statutory construction.” Id. at p. 396, 60 S.Ct. at 340 .”
4 later decisions quote this exact passage · from the majority““ * * * To construe ‘first return’ as meaning the first paper filed as a return, as distinguished from the paper containing a timely amendment, which, when filed is commonly known as the return for the year for which it is filed, is to defeat the purposes of the statute by dissociating the phrase from its context and from the legislative purpose in violation of the most elementary principles of statutory construction.””
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.