United States v. General Dynamics Corp.’s Empirical Analysis
1987
Citation profile
104 federal appellate · 3 district · 6 state decisions
How this case has been cited
Cited by 305 later decisions (1 by the Supreme Court) — most recently March 2022 · most notably Westbrook v. Commissioner (1995), Prabel v. Commissioner (1988)
104 federal appellate · 3 district · 6 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
reviewedthe decision below (from Federal Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 162 · 26 U.S.C. § 446 · 26 U.S.C. § 461 · 26 U.S.C. § 832
Relies on Helvering v. Taylor · United States v. Anderson · Lucas v. American Code Co. · American Petrofina Co. v. Oil, Chemical & Atomic Workers International Union Local No. 4-23 · Security Flour Mills Co. 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 305 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in determining whether an amount has been incurred with respect to any item during any taxable year, the all events test shall not be treated as met any earlier than when economic performance with respect to such item occurs.”
7 later decisions quote this exact passage · from the dissent“... whether a business expense has been “incurred” so as to entitle an accrual-basis taxpayer to deduct it under § 162(a) of the Internal Revenue Code, 26 U.S.C. Sec. 162 (a), is governed by the “all events” test that originated in United States v. Anderson, 269 U.S. 422, 441 [ 46 S.Ct. 181 , 134, 70 L.Ed. 347 ] (1926) ... The test is now embodied in Treas.Reg. 1.461-l(a)(2), 26 C.F.R. § 1.461 -l(a)(2) (1986) which provides that “[u]nder an accrual method of accounting, an expense is deductible for the taxable year in which all events have occurred which determine the fact of. liability and the amount thereof can be determined with reasonable accuracy.””
6 later decisions quote this exact passage · from the majority“based on events that have not occurred by the close of the taxable year.”
6 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.