Motors Insurance v. United States’s Empirical Analysis
530 F.2d 864 · 1976
Citation profile
3 state decisions
How this case has been cited
Cited by 14 later decisions — most recently January 1992
3 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.
Relationships
Applies 26 U.S.C. § 119 · 26 U.S.C. § 122 · 26 U.S.C. § 862 · 28 U.S.C. § 1491
Relies on Commissioner of Internal Revenue v. South Texas Lumber Co · Goss v. Board of Education · Libson Shops, Inc., v. Koehler, District Director of Internal Revenue · Lewyt Corporation v. Commissioner of Internal Revenue · Manning v. Seeley Tube & Box Co.
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"(a) Except as otherwise provided in this section, the following taxes shall be allowed as a deduction for the taxable year within which paid or accrued ... (3) State and local, and foreign, income, war profits, and excess profits taxes ...””
2 later decisions quote this exact passage“(a) Allowance of credit. If the taxpayer chooses to have the benefits of this subpart, the tax imposed by this chapter shall, subject to the limitation of section 904, be credited with the amounts provided in the applicable paragraph of subsection (b) plus, in the case of a corporation, the taxes deemed to have been paid under sections 902 and 960. Such choice for any taxable year may be made or changed at any time before the expiration of the period prescribed for making a claim for credit or refund of the tax imposed by this chapter for such taxable year... . (b) Amount allowed. Subject to the limitation of section 904, the following amounts shall be allowed as the credit under subsection (a): (1) Citizens and domestic corporations. In the case of a citizen of the United States and of a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States; ...”
1 later decision quote this exact passage“SEC. 862(b). Taxable Income From Sources Without United States.— From the items of gross income specified in subsection (a) there shall be deducted the expenses, losses, and other deductions properly apportioned or allocated thereto, and a ratable part of any expenses, losses, or other deductions which cannot definitely be allocated to some item or class of gross income. The remainder, if any, shall be treated in full as taxable income from sources without the United States.”
1 later decision quote this exact passage
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.