Woodward v. Commissioner’s Empirical Analysis
1970
Citation profile
305 federal appellate · 18 district · 17 state decisions
How this case has been cited
Cited by 868 later decisions (16 by the Supreme Court) — most recently March 2025 · most notably Indopco, Inc. v. Commissioner (1992), Neely v. Commissioner (1985)
305 federal appellate · 18 district · 17 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
reviewedFred W. Woodward and Elsie M. Woodward, F. R. Woodward and M. Jeanne Woodward v. Commissioner of Internal Revenue (from Eighth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 212 · 26 U.S.C. § 263 (Interest Equalization Tax Act)
Relies on United States v. Gilmore · Helvering v. Winmill · United States v. Hilton Hotels Corp. · Spreckels 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 868 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[Uncertainty is not called for in applying the regulation that makes the ‘cost of acquisition’ of a capital asset a capital expense. In our view application of [that] regulation to litigation expenses involves the simpler inquiry whether the origin of the claim litigated is in the process of acquisition itself.””
20 later decisions quote this exact passage · from the majority“The policy behind 26 C.F.R. § 1.212 -l(k) is that expenses incurred in acquiring income-producing property — such as brokerage fees incurred in the process of acquiring stocks are “part of the cost of the property,” id., and are therefore treated as non-deductible capital expenditures. These expenditures are added to the basis of the capital asset in connection with which they are incurred, and are taken into account for tax purposes either through depreciation of the asset or through reduction of the capital gain (or augmentation of the loss) when the asset is sold.”
17 later decisions quote this exact passage · from the majority“management, conservation, or maintenance”
9 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.