Healy v. Commissioner’s Empirical Analysis
1953
Citation profile
345 federal appellate · 6 district · 9 state decisions
How this case has been cited
Cited by 612 later decisions (13 by the Supreme Court) — most recently October 2021 · most notably James v. United States (1961), American Automobile Association v. United States (1961)
345 federal appellate · 6 district · 9 state decisions
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 of Internal Revenue v. Hartfield. Commissioner of Internal Revenue v. Healy (from Second Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1111 · 26 U.S.C. § 275 · 26 U.S.C. § 311 · 26 U.S.C. § 41 · 26 U.S.C. § 42 · 26 U.S.C. § 44
Relies on Eisner v. Macomber · North American Oil Consolidated v. Burnet · Burnet v. Sanford & Brooks Co. · Rutkin v. United States
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 612 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[w]hen the event proving the deduction improper occurs after the close of the taxable year, even if the statute of limitations has not run, the Commissioner’s proper remedy is to invoke the tax benefit rule and require inclusion in the later year rather than to re open [sic] the earlier year .... Changes on audit reflect the proper tax treatment of items under the facts as they were known at the end of the taxable year. The tax benefit rule is addressed to a different problem — ’that of events that occur after the close of the taxable year [emphasis in original].... “Congress has enacted an annual accounting system under which income is counted up at the end of éach year. It would be disruptive of an orderly collection of the revenue to rule that the accounting must be done over again to reflect events occurring after the year for which the accounting is made, and tvould violate the spirit of the annual accounting system.””
10 later decisions quote this exact passage · from the majority“[i]f a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.”
8 later decisions quote this exact passage · from the majority“when funds are received and treated by a taxpayer as belonging to him.”
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.