Parsons v. Smith’s Empirical Analysis
1959
Citation profile
148 federal appellate · 12 district · 6 state decisions
How this case has been cited
Cited by 321 later decisions (7 by the Supreme Court) — most recently December 2014 · most notably Paragon Jewel Coal Company v. Commissioner of Internal Revenue (1965), Wood v. United States (1967)
148 federal appellate · 12 district · 6 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
reviewedParsons v. Smith (from Third Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 114 · 26 U.S.C. § 23
Relies on Palmer v. Bender · Abel v. United States · United States v. Ludey · Commissioner v. Southwest Exploration Co. · Anderson v. Helvering
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 321 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(1) that [the contract miners] investments were in their equipment, all of which was movable — not in the coal in place; (2) that their investments in equipment were recoverable through depreciation — not depletion; (3) that the contracts were completely terminable without cause on short notice; (4) that the landowners did not agree to surrender and did not actually surrender to [the contract miners] any capital interest in the coal in place; (5) that the coal at all times, even after it was mined, belonged entirely to the landowners, and that [the contract miners] * * * were not to have any part of the proceeds of the sale of the coal, but, on the contrary, they were to be paid a fixed sum for each ton mined and delivered * * * ; and (7) that [the contract miners], thus, agreed to look only to the landowners for all sums to become due them under their contracts.” 9”
8 later decisions quote this exact passage · from the majority“(b) Economic interest . (1) Annual depletion deductions are allowed only to the owner of an economic interest in mineral deposits or standing timber. An economic interest is possessed in every case in which the taxpayer has acquired by investment any interest in mineral in place or standing timber and secures, by any form of legal relationship, income derived from the extraction of the mineral or severance of the timber, to which he must look for a return of his capital.”
3 later decisions quote this exact passage · from the majority“But the phrase `economic interest' is not to be taken as embracing a mere economic advantage derived from production, through a contractual relation to the owner, by one who has no capital investment in the mineral deposit.”
3 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.