Nat Harrison Assoc., Inc. v. Commissioner’s Empirical Analysis
1964
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 104 later decisions — most recently November 2020 · most notably Zmuda v. Commissioner (1982), Estate of Horvath v. Commissioner (1973)
7 federal appellate · 1 district ·
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
Applies 26 U.S.C. § 691 · 41 U.S.C. § 15
Relies on Helvering v. Taylor · Helvering v. Horst · Lucas v. Earl · Rodriguez v. New York · Moline Properties, Inc. 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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“all interest paid or accrued within the taxable year on indebtedness.”
2 later decisions quote this exact passage · from the majority“While respondent did not mention his reliance on section 482 in either the notices of deficiencies or his pleadings, it is obvious that petitioners were not taken by surprise by this contention and, while such pleading hardly complies with the spirit of the rules of pleading of this Court, we think respondent may rely on section 482 in this case without amending his pleadings. Cf. Commissioner v. Chelsea Products, 197 F. 2d 620 (C.A. 3, 1952), affirming 16 T.C. 840 (1951) ; Arthur Sorin, 29 T.C. 959 (1958), affirmed per curiam 271 F. 2d 741 (C.A. 2, 1959).***”
1 later decision quote this exact passage“Whether the primary reason for its existence and conduct of business was to avoid U.S. taxes or to permit more economical performance of contracts through use of native labor, or a combination of these and other reasons, makes no difference in this regard. Any one of these reasons would constitute a valid business purpose for Its existence and conduct of business as long as it actually conducted business. * * *”
1 later decision 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.