Dowell v. United States’s Empirical Analysis
522 F.2d 708 · 1975
Citation profile
17 federal appellate ·
How this case has been cited
Cited by 81 later decisions — most recently April 2018 · most notably Meridian Wood Products Co. v. United States (1984), BJR Corp. v. Commissioner (1976)
17 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. § 162 · 26 U.S.C. § 274
Relies on Cohan v. Commissioner · Continental Motors Corp. v. Continental Aviation Corp. · Paramount-Richards Theatres, Inc. v. Commissioner of Internal Revenue · Fulton National Bank v. Tate
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 81 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[must] substantiate[] by adequate records or by sufficient evidence corroborating the taxpayer's own statement”
10 later decisions quote this exact passage · from the majority“(b)y his own statement, whether written or oral, containing specific information in detail as to such element; and (ii) By other corroborative evidence sufficient to establish such element.”
6 later decisions quote this exact passage · from the majority“[A] taxpayer must substantiate each element of an expenditure or use ... by [1] adequate records or [2] by sufficient evidence corroborating his own statement. ... A contemporaneous log is not required, but a record of the elements of an expenditure or of a business use of listed property made at or near the time of the expenditure or use, supported by sufficient documentary evidence, has a high degree of credibility not present with respect to a statement prepared subsequent thereto when generally there is a lack of accurate recall. Thus, the corroborative evidence required to support a statement not made at or near the time of the expenditure or use must have a high degree of probative value to elevate such statement or evidence to the level of credibility reflected by a record made at or near the time of the expenditure or use supported by sufficient documentary evidence. The substantiation requirements of section 274(d) are designed to encourage taxpayers to maintain the records, together with documentary evidence, as provided in paragraph (c)(2) of this section [entitled “Substantiation by adequate records ”].”
5 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.