Donald L. Wilkerson v. Commissioner Of Internal Revenue’s Empirical Analysis
1981
Citation profile
15 federal appellate ·
How this case has been cited
Cited by 39 later decisions — most recently October 2014 · most notably Aboussie v. United States (1985), Blitzer v. United States (1982)
15 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. § 163
Relies on Minnesota Tea Co. v. Helvering · Don Williams Company v. Commissioner of Internal Revenue · Helvering v. Price · Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. Goodstein · G. Douglas Burck and Marjorie W. Burck v. Commissioner of Internal Revenue
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The fact that the loan proceeds were run through the taxpayers' bank account in a transaction intended to take not more than one business day, does not affect the substance of the transaction.”
4 later decisions quote this exact passage · from the majority“all interest paid or accrued within the taxable year on indebtedness.”
4 later decisions quote this exact passage · from the majority“[a] cash-basis taxpayer 'pays' interest only when he pays cash or its equivalent to his lender.”
3 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.