Fribourg Navigation Company v. Commissioner of Internal Revenue’s Empirical Analysis
1966
Citation profile
93 federal appellate · 18 district · 14 state decisions
How this case has been cited
Cited by 265 later decisions (19 by the Supreme Court) — most recently April 2009 · most notably United States v. Correll (1967), Securities & Exchange Commission v. Sloan (1978)
93 federal appellate · 18 district · 14 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
reviewedFribourg Navigation Co. v. Commissioner of Internal Revenue (from Second Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1245 · 26 U.S.C. § 167 · 26 U.S.C. § 7805
Relies on Commissioner of Internal Revenue v. Glenshaw Glass Company · Automobile Club of Mich. v. Commissioner · Higgins v. Commissioner · Dixon v. Unied States · Helvering v. Winmill
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 265 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is, of course, undisputed that the Commissioner may require redetermination of useful life or salvage value when it becomes apparent that either of these factors has been miscalculated. The fact of sale of an asset at an amount greater than its depreciated basis may be evidence of such a miscalculation.”
3 later decisions quote this exact passage · from the majority“(T)ax law has long recognized the accounting concept that depreciation is a process of estimated allocation which does not take account of fluctuations in valuation through market appreciation.”
3 later decisions quote this exact passage · from the majority“This carefully constructed regulatory scheme provides no basis for disallowances of depreciation when no challenge has been made to the reasonableness or accuracy of the original estimates of useful life or salvage value.”
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.