Fuller v. Commissioner’s Empirical Analysis
1953
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 26 later decisions — most recently December 2001 · most notably Samuel Towers v. Commissioner of Internal Revenue, and Three Related Cases (1957), Stamos v. Commissioner (1954)
2 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
Relies on Burnet v. Clark · Civil Aeronautics Board v. Summerfield · Commissioner v. Smith · Campbell v. Commissioner · Sage 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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Over a 30-year period petitioner has promoted, financed, and managed several corporations and has been interested in and has advanced capital to several other business enterprises. But this business activity on the part of the petitioner was spread over the years, most of it taking place long prior to 1947. Petitioner has not shown that his activities in promoting, financing, managing, and making loans to corporations or business enterprises were sufficiently extensive in and around 1947 and 1948 to constitute a trade or business in and of itself. * * *”
1 later decision quote this exact passage“The authority contained in such cases as Weldon D. Smith, 17 T.C. 135 , revd. 203 Fed. (2d) 310 , Henry E. Sage, 15 T.C. 299 , and Vincent C. Campbell, 11 T.C. 510 , is applicable only to the exceptional situations where the taxpayer's activities in promoting, financing, managing, and making loans to a number of corporations have been regarded as so extensive as to constitute a businesss separate and distinct from the business carried on by the corporations themselves. * * *”
1 later decision quote this exact passage“A trade or business requires the expenditure of a substantial amount of time and effort, and usually entails keeping books and maintaining an office.”
1 later decision quote this exact passage
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.