Hochschild v. Commissioner’s Empirical Analysis
161 F.2d 817 · 1947
Citation profile
46 federal appellate · 4 district ·
How this case has been cited
Cited by 89 later decisions (1 by the Supreme Court) — most recently May 1995 · most notably Woodward v. Commissioner (1970), Folker v. Johnson (1956)
46 federal appellate · 4 district ·
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
Relies on Welch v. Helvering · Cohan v. Commissioner · Commissioner of Internal Revenue v. Heininger · Bingham's Trust v. Commissioner of Internal Revenue · Kornhauser v. United States
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 89 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““He thereby but fended off an abortive attack upon the conduct of his business as a fiduciary and by freeing himself from liability to his corporation to account for such conduct put all of his property beyond the reach of his then accusers.” 161 F.2d at 819 .”
7 later decisions quote this exact passage · from the majority““Sec. 1.212-1 NONTRADE OR NON-BUSINESS EXPENSES “(a) An expense may be deducted under Section 212 only if— “(1) It lias been paid or incurred by the taxpayer during the taxable year (i) for the production or collection of income which, if and when realized, will be required to be included in income for Federal income tax purposes, or (ii) for the management, conservation or maintenance of property held for the production of such income, or (iii) in connection with the determination, collection or refund of any tax; and “(2) It is an ordinary and necessary expense for any of the purposes stated in subparagraph (1) of this paragraph.””
2 later decisions quote this exact passage · from the majority“the ordinary and necessary expenses [of an individual] paid or incurred ... for the production or collection of income.”
2 later decisions 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.