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← 321 U.S. 281 - Security Flour Mills Co. v. Commissioner

Security Flour Mills Co. v. Commissioner’s Empirical Analysis

321 U.S. 281 · 1944

Citation profile

1,016
cited by 1,016 later decisions
31
cited 31 times by the Supreme Court
5
states following
April 2019
most recently cited

464 federal appellate · 18 district · 21 state decisions

How this case has been cited

Cited by 1,016 later decisions (31 by the Supreme Court) — most recently April 2019 · most notably Bingham's Trust v. Commissioner of Internal Revenue (1945), Commissioner v. Hansen (1959)

464 federal appellate · 18 district · 21 state decisions

424019441950196019701980199020002010decided

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 v. Security Flour Mills Co. (from Tenth Circuit Court of Appeals)

Relationships

Relies on Dobson v. Commissioner · Burnet v. Sanford & Brooks Co. · Tait v. Western Maryland Railway Co. · Dixie Pine Products Co. v. Commissioner

Cited together with Dixie Pine Products Co. v. Commissioner · United States v. Anderson · Lucas v. American Code Co. · North American Oil Consolidated v. Burnet · Reynolds v. Cooper

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 1,016 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “It is the essence of any system of taxation that it should produce revenue ascertainable, and payable to the government, at regular intervals. Only by such a system is it practicable to produce a regular flow of income and apply methods of accounting, assessment, and collection capable of practical operation.”
    40 later decisions quote this exact passage · from the majority
  2. “It is settled by many decisions that a taxpayer may not accrue an expense the amount of which is unsettled or the liability for which is contingent, and this principle is fully applicable to a tax, liability for which the taxpayer denies, and payment whereof he is contesting. * * *”
    9 later decisions quote this exact passage · from the majority
  3. “create 'a divided and inconsistent method of accounting not properly to be denominated either a cash or an accrual system'”
    5 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.