Commissioner of Internal Revenue v. Lincoln Savings and Loan Association’s Empirical Analysis
1971
Citation profile
153 federal appellate · 12 district · 20 state decisions
How this case has been cited
Cited by 661 later decisions (16 by the Supreme Court) — most recently November 2019 · most notably Indopco, Inc. v. Commissioner (1992), Frank Lyon Co. v. United States (1978)
153 federal appellate · 12 district · 20 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
reviewedLincoln Savings & Loan Ass'n v. Commissioner (from Ninth Circuit Court of Appeals)
Relationships
Applies 12 U.S.C. § 1421 (Federal Home Loan Bank Act) · 12 U.S.C. § 1426 · 26 U.S.C. § 162
Relies on Welch v. Helvering · Deputy v. du Pont · Commissioner of Internal Revenue v. Heininger · Douglas v. Alabama · Cree v. Goldstein
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 661 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an item must (1) be 'paid or incurred during the taxable year,' (2) be for 'carrying on any trade or business,' (3) be an 'expense,' (4) be a 'necessary' expense, and (5) be an 'ordinary' expense.”
36 later decisions quote this exact passage · from the majority“[T]he presence of an ensuing benefit that may have some future aspect is not controlling; many expenses concededly deductible have prospective effect beyond the taxable year.”
24 later decisions quote this exact passage · from the majority“only the minimal requirement that the expense be `appropriate and helpful' for `the development of the [taxpayer's] business.'”
11 later decisions quote this exact passage · from the majoritye.g. Bruns v. Comm'r · Linzy v. Comm'r
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.