Trinity Construction Co. v. United States’s Empirical Analysis
424 F.2d 302 · 1970
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 28 later decisions — most recently June 1993 · most notably Southern Pacific Transp. Co. v. Commissioner (1980), Putoma Corp. v. Commissioner (1979)
12 federal appellate ·
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. § 404 · 26 U.S.C. § 461
Relies on Security Flour Mills Co. v. Commissioner · Reynolds v. Cooper · Brown v. Helvering · Ruth T. Lengsfield, Coralie Mayer Lengsfield and Blanche L. Brown v. Commissioner of Internal Revenue · Estate of B. F. Whitaker 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Under an accrual method of accounting, an expense is deductible for the taxable year in which all the events have occurred which determine the fact of the liability and the amount thereof can be determined with reasonable accuracy.” Treas.Reg. § 1.461-1(a)(2) (1970), promulgated by T.D. 6282,1958-1 Cum.Bull. 215, 22 F.R. 10686 , Dec. 25, 1957, 26 C.F.R. § 1.461-1 (a)(2) (1970).”
4 later decisions quote this exact passage · from the majority“(a) General rule. — If contributions are paid by an employer to or under a stock bonus, pension, profit-sharing, or annuity plan, or if compensation is paid or accrued on account of any employee under a plan deferring the receipt of such compensation, such contributions or compensation shall not be deductible under section 162 (relating to trade or business expenses) or section 212 (relating to expenses for the production of income) ; but, if they satisfy the conditions of either of such sections, they shall be deductible under this section, * * *.” 26 U.S.C.A. § 404 (a). “Trade or business expenses. (a) In general. — There shall be allowed ns a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business * * 26 U.S.C.A. § 162 .”
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.