United States v. Consolidated Edison Co. of NY’s Empirical Analysis
1961
Citation profile
141 federal appellate · 12 district · 8 state decisions
How this case has been cited
Cited by 356 later decisions (9 by the Supreme Court) — most recently January 2012 · most notably American Automobile Association v. United States (1961), United States v. Hughes Properties, Inc. (1986)
141 federal appellate · 12 district · 8 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
reviewedConsolidated Edison Co. of New York, Inc. v. United States (from Second Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1311 · 26 U.S.C. § 23
Relies on United States v. Anderson · Lucas v. American Code Co. · Burnet v. Sanford & Brooks Co. · Security Flour Mills Co. v. Commissioner · Dixie Pine Products Co. 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 356 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is also true that in advance of the assessment of a tax, all the events may occur which fix the amount of the tax and determine the liability of the taxpayer to pay it.”
7 later decisions quote this exact passage · from the majority“It has never been questioned that a taxpayer who accounts on the accrual basis may, and should, deduct from gross income a liability which really accrues in the taxable year. It has long been held that, in order truly to reflect the income of a given year, all the events must occur in that year which fix the amount and the fact of the taxpayer's liability for items of indebtedness deducted though not paid; and this cannot be the case where the liability is contingent and is contested by the taxpayer. * * * It must, in the circumstances, await the event of the state court litigation and might claim a deduction only for the taxable year in which its liability for the tax was finally adjudicated.”
4 later decisions quote this exact passage · from the majoritye.g. Estate of Goodall v. Commissioner · Estate of Robert A. Goodall, Deceased, C. M. Goodall v. Commissioner of Internal Revenue, Estate of Robert A. Goodall, Deceased, Clarice M. Goodall v. Commissioner of Internal Revenue, (Two Cases). Estate of Robert A. Goodall, Deceased, Clarice M. Goodall, and Clarice M. Goodall v. Commissioner of Internal Revenue, C. M. Goodall v. Commissioner of Internal Revenue, Good-All Electric Mfg. Co. v. Commissioner of Internal Revenue“the 'touchstone' for determining the year in which an item of deduction accrues”
2 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.