Kelly v. Commissioner’s Empirical Analysis
1956
Citation profile
23 federal appellate ·
How this case has been cited
Cited by 59 later decisions — most recently September 2021 · most notably Estate of Hutchen Upshaw, Deceased, Ardenia Upshaw, Administratrix, and Ardenia Upshaw, Individually v. Commissioner of Internal Revenue, Estate of Hutchen Upshaw, Deceased, Ardenia Upshaw, Administratrix,petitioner-Appellant v. Commissioner of Internal Revenue (1969), Boagni v. Commissioner (1973)
23 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. § 212
Relies on New Colonial Ice Co. v. Helvering · Interstate Transit Lines v. Commissioner · Rassenfoss v. Commissioner · Brown v. Commissioner of Internal Revenue
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“for the management, conservation, or maintenance of property held for the production of income.”
2 later decisions quote this exact passage“has given the courts considerable difficulty.”
1 later decision quote this exact passage“for the production or collection of income”
1 later decision quote this exact passagee.g. Edgar v. Comm'r
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.