Indianapolis Power & Light Co. v. Commissioner’s Empirical Analysis
857 F.2d 1162 · 1988
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 15 later decisions (1 by the Supreme Court) — most recently November 2009
8 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.
Appellate journey
Relationships
Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on North American Oil Consolidated v. Burnet · Commissioner v. Tufts · Illinois Power Co. v. Commissioner · Busch v. Commissioner of Internal Revenue · Gilken Corp. v. Commissioner
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to [pay tax on], even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore its equivalent.”). Relying on this principle courts have generally held that a public utility must recognize a security deposit as an”
1 later decision quote this exact passage · from the majority“as the interest rate paid on a deposit to secure income begins to approximate the return that the recipient would be expected to make from 'the use' of the deposit amount, the deposit begins to serve purposes that comport more squarely with a security deposit.”
1 later decision quote this exact passage · from the majority“the proper approach to determining the appropriate tax treatment of a customer deposit is to look at the primary purpose of the deposit based on all the facts and circumstances. . . .”
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.