Patterson v. Pizitz, Inc.’s Empirical Analysis
353 F.2d 267 · 1965
Citation profile
16 federal appellate ·
How this case has been cited
Cited by 28 later decisions (1 by the Supreme Court) — most recently October 1983 · most notably Thor Power Tool Company v. Commissioner of Internal Revenue (1979), Webb v. Commissioner (1968)
16 federal appellate ·
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.
Relationships
Applies 26 U.S.C. § 166
Relies on Lucas v. Kansas City Structural Steel Co. · Swift & Co. v. Morgan & Sturdivant · Krim-Ko Corp. v. Commissioner · Maverick-Clarke Litho Co. v. Commissioner · United States v. Byck
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In lieu of any deduction under subsection (a), there shall be allowed (in the discretion of the Secretary or his delegate) a deduction for a reasonable addition to a reserve for bad debts.”
3 later decisions quote this exact passage“The proof here showed only that the Commissioner, in effect, reduced the reserve to accord with taxpayer’s loss experience in the light of existing circumstances bearing on credit losses. There are, of course, strong factually based arguments against his judgment in so doing but they fall short of establishing arbitrariness. It follows that the District Court erred in failing to grant the motion of the Director for judgment notwithstanding the verdict. Id. at 270.”
1 later decision quote this exact passage“the evidence on balance . . . does not rise to that level of proof which would show an abuse of discretion on the part of the Commissioner.”
1 later decision quote this exact passage
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.