F. M. Williams v. George D. Patterson, District Director of Internal Revenue’s Empirical Analysis
286 F.2d 333 · 1961
Citation profile
23 federal appellate ·
How this case has been cited
Cited by 41 later decisions — most recently December 2016 · most notably James v. United States (1962), Steinhort v. Commissioner of Internal Revenue (1964)
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.
Appellate journey
reviewedthe decision below (from Texas Eastern District Court)
Relationships
Relies on Commissioner of Internal Revenue v. Flowers · Peurifoy v. Commissioner · Flying Tiger Line, Inc. v. Philippine Air Lines, Inc. · Crowther 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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“while away from home in the pursuit of a trade or business”
6 later decisions quote this exact passage · from the majority““We note, first, that Congress expressly repudiated a narrow view of the deduction. The Act allows the full amount expended to be deductible, not just the excess of expenditures over the amounts that would ordinarily be spent at home. Moreover, there is no express statutory limitation, even as to reasonableness. Second, we note particularly that there is no language in the statute limiting its application to ‘expenses incurred while * * * away from home overnight’. The ‘overnight’ gloss was dreamed up by the Department. Third, there is nothing in the statute indicating any congressional intent that ‘away from home’ means either overnight or away from home for a period substantially longer than an ordinary working day, or that it means ‘a trip on which the taxpayer’s duties [in his released time] required him to obtain necessary sleep away from his home terminal’.””
3 later decisions quote this exact passage · from the majority“Between these extremes, however, there are innumerable borderline situations, * * *, that cannot be measured by the length and breadth of a thumb [rule of thumb].”
2 later decisions 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.