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← 139 TC 19 - Olive v. Commissioner

Olive v. Commissioner’s Empirical Analysis

2012

Citation profile

49
cited by 49 later decisions
May 2020
most recently cited

Relationships

Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · Helvering v. Taylor · Cohan v. Commissioner · HIGBEE 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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “to be engaged in a trade or business for purposes of section 162 , [a taxpayer] must be involved in the activity with continuity and regularity and the taxpayer's primary purpose for engaging in the activity must be for income or profit.”
    1 later decision quote this exact passage · from the majority
  2. “trade or business (or the activities which comprise such trade or business) consists of trafficking in controlled substances * * * which is prohibited by Federal law”
    1 later decision quote this exact passage · from the majority
  3. “is not a deduction within the meaning of sec. 162(a) but is subtracted from gross receipts in determining a taxpayer's gross income.”
    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.