Brown Shoe Co. v. Commissioner’s Empirical Analysis
339 U.S. 583 · 1950
Citation profile
104 federal appellate · 6 district ·
How this case has been cited
Cited by 221 later decisions (4 by the Supreme Court) — most recently July 2020 · most notably United States v. Chicago, Burlington & Quincy Railroad (1973), Sparks Nugget, Inc. v. Commissioner (1972)
104 federal appellate · 6 district ·
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. Brown Shoe Co. (from Eighth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 723
Relies on Detroit Edison Co. v. Commissioner · LaBelle Iron Works v. United States · Texas Ry Co v. United States · Reisinger 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 221 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Because in the Detroit Edison case ‘The payments were to the customer the price of the service,’ the Court concluded that ‘it overtaxes imagination to regard the farmers and other customers who furnished these funds as makers either of donations or contributions to the Company.' Since in this ease there are neither customers nor payments for service, we may infer a different purpose in the transactions between petitioner and the community groups. The contributions to petitioner were provided by citizens of the respective communities who neither sought nor could have anticipated any direct service or recompense whatever, their only expectation being that such contributions might prove advantageous to the community at large. Under these circumstances the transfers manifested a definite purpose to enlarge the working capital of the company.” ( 339 U.S. at 591 , 70 S.Ct. at 824 .)”
4 later decisions quote this exact passage · from the majority“(T)he assets received . . . are being used by the taxpayer in the operation of its business. They will in time wear out, and if (the taxpayer) is to continue in business, the physical plant must eventually be replaced. Looking as they do toward business continuity, the Internal Revenue Code's depreciation provisions—and especially those which provide for a substituted rather than a cost basis—would seem to envision allowance of a depreciation deduction in situations like this. . . .”
1 later decision quote this exact passage · from the majority“the payment of cash and the transfer of other property to [a corporation] by certain community groups as an inducement to the location or expansion of [the corporation's] operations in the communities”
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.