Patton v. Commissioner’s Empirical Analysis
168 F.2d 28 · 1948
Citation profile
19 federal appellate ·
How this case has been cited
Cited by 35 later decisions — most recently November 1995 · most notably Kennedy v. Commissioner (1982), Bishop v. Commissioner of Internal Revenue (1965)
19 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.
Relationships
Applies 26 U.S.C. § 23
Relies on Hormel v. Helvering · Botany Worsted Mills v. United States · Helvering v. Tex-Penn Oil Co. · Wilmington Trust Co. v. Helvering · Tracy 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The nature of the services to be performed, the responsibilities they entail, the time required of the employee in the discharge of his duties, his capabilities and training, and the amount of compensation paid in proportion to net profits.”
3 later decisions quote this exact passage · from the majority“Probably one of the most important factors in determining the reasonableness of compensation is the amount paid to similar employees by similar concerns engaged in similar industries.”
1 later decision quote this exact passage · from the majority“allowance for salaries or other compensation for”
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.