Chattanooga Automobile Club v. Commissioner’s Empirical Analysis
182 F.2d 551 · 1950
Citation profile
17 federal appellate · 1 state decisions
How this case has been cited
Cited by 36 later decisions (1 by the Supreme Court) — most recently August 1988 · most notably Automobile Club of Mich. v. Commissioner (1957), United States v. Jefferson County Board of Education (1966)
17 federal appellate · 1 state decisions
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. § 101
Relies on Higgins v. Commissioner · Better Business Bureau of Washington, D. C., Inc. v. United States · Helvering v. Reynolds · Helvering v. Wilshire Oil Co. · United States v. Dakota-Montana Oil 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is thought that there must be at least some sort of commingling of members to constitute a club which is exempted by subsection 9 of section 101 of the Internal Revenue Code [now 26 U.S.C. § 501 (c)(7)], ****** The members of these two automobile clubs certainly did not commingle. Neither club had a club house, but only an office for the transaction of its business, not designed for meetings of the entire membership. There was only an annual meeting for members, attended but by a few, to elect directors of the Chattanooga club and trustees for the Warren club. Obviously in paying the price for original membership and in subsequently paying $10 annual dues, no person had in mind that he would associate personally with others for any social, civic, political, business, or any other purpose. He was merely banding with other people to purchase at a reduced cost services in connection with the use of his automobile. These services to members were performed entirely by paid employees. Amounts expended by the clubs for general welfare service were quite insignificant when compared to expenditures for rendering services to club members.”
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.