Alpha Medical, Inc. v. Commissioner’s Empirical Analysis
172 F.3d 942 · 1999
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 16 later decisions — most recently May 2023
6 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. § 162
Relies on United States v. United States Gypsum Co. · Welch v. Helvering · Helvering v. National Grocery Co. · Botany Worsted Mills v. United States · Lucas v. Ox Fibre Brush Co.
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Examining economic conditions during the tax years in question helps to determine whether the success of a business is attributable to general economic conditions as opposed to the efforts and business acumen of the employees.”
1 later decision quote this exact passage · from the majority“It is, in general, just to assume that reasonable and true compensation is only such amount as would ordinarily be paid for like services by like enterprises under like circumstances.”
1 later decision quote this exact passage · from the majority“did not exceed the amount needed to remedy prior years of undercompensation, and was therefore reasonable”
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.