1 F. Supp. 2d 12 - Biddulph v. Callahan’s Empirical Analysis
1998
Citation profile
1 district ·
Relationships
Applies 26 U.S.C. § 162 · 42 U.S.C. § 402 (§ 202 of the Social Security Act of 1935) · 42 U.S.C. § 405 (§ 205 of the Social Security Act of 1935) · 42 U.S.C. § 411 (§ 211 of the Social Security Act of 1935) · 42 U.S.C. § 413 (§ 213 of the Social Security Act of 1935)
Relies on Deputy v. du Pont · Allentown MacK Sales & Service, Inc. v. National Labor Relations Board · Commissioner of Internal Revenue v. P Groetzinger · Binion v. Chater · Portland Golf Club 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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“not every income-producing and profit-making endeavor constitutes a trade or business. The income tax law, almost from the beginning, has distinguished between a business or trade, on the one hand, and transactions entered into for profit but not connected with business or trade, on the other. Congress distinguished the broad range of income or profit producing activities from those satisfying the narrow category of trade or business. We accept the fact that to be engaged in a trade or business, the taxpayer must be involved in the activity with continuity and regularity and that the taxpayer’s primary purpose for engaging in the activity must be for income or profit. A sporadic activity, a hobby, or an amusement diversion does not qualify.”
1 later decision quote this exact passage · from the majority“(a) Information contained in the evidence was given by a person in a position to know the facts; (b) There was any reason to give false information when the evidence was created; (c) Information contained in the evidence was given under oath, or with witnesses present, or with the knowledge there was a penalty for giving false information; (d) The evidence was created at the time the event took place or shortly thereafter; (e) The evidence has been altered or has any erasures on it; and (f) Information contained in the evidence agrees with other available evidence, including [the Commissioners’s] records.”
1 later decision quote this exact passage · from the concurrence
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.