Putoma Corp. v. Commissioner’s Empirical Analysis
1979
Citation profile
21 federal appellate ·
How this case has been cited
Cited by 93 later decisions (1 by the Supreme Court) — most recently September 2019 · most notably Hillsboro National Bank v. Commissioner (1983), Southern Pacific Transp. Co. v. Commissioner (1980)
21 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. § 118 · 26 U.S.C. § 127
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · United States v. Anderson · Old Colony Trust Co. v. Commissioner · Dobson v. Commissioner · Burnet v. Sanford & Brooks 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 93 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Only a word need be said with reference to the contention that the tax upon munitions manufactured and sold in 1916 did not accrue until 1917. In a technical legal sense it may be argued that a tax does not accrue until it has been assessed and becomes due; but it is also true that in advance of the assessment of a tax, all the events may occur which fix the amount of the tax and determine the liability of the taxpayer to pay it. In this respect, for purposes of accounting and of ascertaining true income for a given accounting period, the munitions tax here in question did not stand on any different footing than other accrued expenses appearing on appellee’s books. * * *”
1 later decision quote this exact passage · from the majority“(4) Recovery exclusion. The term 'recovery exclusion', with respect to a bad debt, prior tax, or delinquency amount, means the amount, determined in accordance with regulations prescribed by the Secretary or his delegate, of the deductions or credits allowed, on account of such bad debt, prior tax, or delinquency amount, which did not result in a reduction of the taxpayer's tax under this subtitle . . . reduced by the amount excludable in previous taxable years with respect to such debt, tax, or amount under this section.”
1 later decision quote this exact passage · from the majority“judgment of the majority of the directors of the company, that the company has sufficient cash reserve in order to pay the salary.”
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.