Sutter v. Commissioner’s Empirical Analysis

Citation profile

14 federal appellate · 1 district ·

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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “different from or in excess of that which would have been made for the taxpayer's personal purposes.”

   7 later decisions quote this exact passage
   e.g. Commissioner of Internal Revenue v. Everett and Mary C. Doak · King, Quirk & Co. v. Commissioner

2. “* * * When a taxpayer in the course of supplying food or entertainment or making other outlays customarily regarded as ordinary and necessary includes an amount attributable to himself or his family, such as the payment for his own meals, is that portion of the expenditure an ordinary and necessary business expense on the one hand or a nondeductible personal item on the other?”

   1 later decision quote this exact passage
   e.g. Scott v. Commissioner

3. “* * * regard an allocation as required because it is evident that only a part of these conceded expenditures may be characterized as the ordinary and necessary consequences of petitioner's trade or business.”

   1 later decision quote this exact passage
   e.g. Briggs v. Commissioner