Helvering v. Horst’s Empirical Analysis
311 U.S. 112 · 1940
Citation profile
1,281 federal appellate · 51 district · 73 state decisions
How this case has been cited
Cited by 2,598 later decisions (80 by the Supreme Court) — most recently June 2024 · most notably Commissioner v. Sunnen (1948), Commissioner of Internal Revenue v. Culbertson (1949)
1,281 federal appellate · 51 district · 73 state decisions — followed in 16 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
reviewedHorst v. Commissioner (from Second Circuit Court of Appeals)
Relationships
Relies on Helvering v. Clifford · Lucas v. Earl · Old Colony Trust Co. v. Commissioner · Corliss v. Bowers
Cited together with Lucas v. Earl · Helvering v. Clifford · Helvering v. Eubank · Harrison v. Schaffner · Blair v. Commissioner
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 2,598 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The power to dispose of income is the equivalent of ownership of it. The exercise of that power to procure the payment of income to another is the enjoyment and hence the realization of the income by him who exercises it.”
59 later decisions quote this exact passage · from the majority““And we have held that the dominant purposes of all sections of the revenue laws, including these, is ‘the taxation of income to those who earn or otherwise create the right to receive it and enjoy the benefit of it when paid.’ ””
10 later decisions quote this exact passage · from the majority““There is no doubt that the statute could tax salaries to those who earned them and provide that tile tax could not be escaped by anticipatory arrangements and contracts however skilfully devised to prevent the salary when paid from vesting even for a second in the man who earned it. That seems to us the import of the statute before us and we think that no distinction can be taken according to the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew.””
7 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.