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← 39 BTA 702 - Johnson v. Commissioner

Johnson v. Commissioner’s Empirical Analysis

1939

Citation profile

7
cited by 7 later decisions
January 1956
most recently cited

1 federal appellate ·

How this case has been cited

Cited by 7 later decisions — most recently January 1956

1 federal appellate ·

40193919401950decided

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

Relies on Lucas v. Earl · Corliss v. Bowers · Burnet v. Leininger · Hegeman v. . Moon · Rands 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “and continues: I do hereby promise and agree for myself, my heirs, executors, administrators and assigns to pay to the said Irene W. Johnson, as trustee, and her successor in interest, the sum of $2,625 per year interest upon said borrowed money for and during the natural life of [the sister concerned]. The feature which strikes the reader at once is the absence of any promise to pay the principal. Emil Weitzner, 12 B.T.A. 724 . Yet the existence of a principal debt, not merely an obligation to pay”
    1 later decision quote this exact passage
  2. “is a prerequisite of the deduction. Edwin M. Klein, 31 B.T.A. 910 , 918 , 919 . In both the letter and the acknowledgement there is a significant failure to include any promise to repay principal, not to mention the complete absence of a time for payment. The agreement to pay interest stands alone with no accompanying promise to repay the amount”
    1 later decision quote this exact passage
  3. “acknowledges that the petitioner and her personal representatives are indebted to herself as trustee”
    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.