Allstate Sav. & Loan Asso. v. Commissioner’s Empirical Analysis
1977
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 7 later decisions — most recently August 1995
2 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. § 593 · 26 U.S.C. § 595
Relies on Automobile Club of Mich. v. Commissioner · Crane v. Commissioner · Dixon v. Unied States · Woodward v. Commissioner · United States v. Hilton Hotels Corp.
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An amount realized with respect to acquired property means an amount representing a recovery of capital, such as proceeds from the sale or other disposition of the property, payments on the original indebtedness made by or on behalf of the debtor (including amounts received under an insurance contract with the Federal Housing Administration or a guaranty by the Veterans’ Administration), and collections on a deficiency judgment obtained against the debtor (other than amounts treated as interest under applicable local law).”
1 later decision quote this exact passage“Any amount realized by [a savings and loan association] with respect to [foreclosure] property shall be treated for purposes of this chapter as a payment on account of such indebtedness, and any loss with respect thereto shall be treated as a bad debt to which the provisions of section 166 (relating to allowance of a deduction for bad debt) apply.”
1 later decision quote this exact passage“When the property is ultimately sold or disposed of, the difference between any amount realized and the original or previously reduced debt, is to be treated as ordinary loss or income and is to be charged, or credited, as the case may be, against the reserve for losses on qualifying real property loans.”
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.