Allen v. Commissioner’s Empirical Analysis
1949
Citation profile
12
cited by 12 later decisions
April 1955
most recently cited
Relationships
Relies on Helvering v. Horst · Lucas v. Earl · Commissioner v. Tower · Lusthaus 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The petitioner in the present case did not earn the income in question. It does not appear that capital was a material income-producing factor or that the petitioner's wife contributed services vital to the two partnerships, but that is not determinative where, as here, the income can not be attributed either to capital contributed by the husband or to services performed by him. Simmons v. Commissioner, 164 Fed. (2d) 220 . This is a stronger case for the taxpayer than Kent v. Commissioner, 170 Fed. (2d) 131 .”
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.