White v. Fitzpatrick’s Empirical Analysis
193 F.2d 398 · 1951
Citation profile
19 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 35 later decisions — most recently May 2018 · most notably Furman v. Commissioner (1966), Brooke v. United States (1972)
19 federal appellate · 2 district · 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. § 22 · 26 U.S.C. § 23
Relies on Welch v. Helvering · Commissioner v. Sunnen · Gregory v. Helvering · Deputy v. du Pont · Helvering v. Clifford
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.
“In computing net income there shall be allowed as deductions : (a) Expenses.— (1) Trade or business expenses.— (A) In general. — All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including a reasonable allowance for salaries or other compensation for personal services actually rendered; traveling expenses (including the entire amount expended for meals and lodging) while away from home in the pursuit of a trade or businees; and rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity. * * *”
1 later decision quote this exact passage · from the majority“Gift and retained control must be regarded as inseparable parts of a single transaction, especially since it was only in their sum total that they had any reality in regard to the conduct of [taxpayer’s] business. To isolate them ... is to hide business reality behind paper pretense.”
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.