McDowell v. Ribicoff’s Empirical Analysis
292 F.2d 174 · 1961
Citation profile
29 federal appellate · 5 district ·
How this case has been cited
Cited by 57 later decisions — most recently September 2021 · most notably Fischer v. Commissioner (1968), Snyder v. United States (1982)
29 federal appellate · 5 district ·
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. § 162 · 26 U.S.C. § 23 · 26 U.S.C. § 7852
Relies on Deputy v. du Pont · Flint v. Stone Tracy Co. · Higgins v. Commissioner · United States v. Pyne · City Bank Farmers Trust Co. v. Helvering
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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he phrase `trade or business' [as used in the Tax Code] connotes something more than an act or course of activity engaged in for profit. * * * The phrase * * * must refer not merely to Acts engaged in for profit, but to extensive activity over a substantial period of time during which the Taxpayer holds himself out as selling goods or services.”
6 later decisions quote this exact passage“(a) In General. — There shall be allowed as a deduction all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business, including—”
4 later decisions quote this exact passage“To determine whether the activities of a taxpayer are 'carrying on a business' requires an examination of the facts in each case.”
4 later decisions 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.