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← 3 TC 799 - Johnston v. Commissioner

Johnston v. Commissioner’s Empirical Analysis

1944

Citation profile

16
cited by 16 later decisions
April 1947
most recently cited

3 federal appellate ·

Relationships

Applies 26 U.S.C. § 181

Relies on Helvering v. Clifford · Helvering v. Horst · Corliss v. Bowers · Douglas v. Willcuts · Burnet v. Wells

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

  1. “Unlike Mead v. Commissioner, 131 Fed. (2d) 323; Schroder v. Commissioner, supra; and Earp v. Jones, 131 Fed. (2d) 292, relied on by respondent, this was not an arrangement between only a husband and wife to engage in an exclusively or predominantly personal service business, the income from which was due entirely to the husband’s personal efforts. Manifestly, the income of petitioner’s wife was an attribute of and flowed from her capital interest in the business rather than from the efforts and energy expended by petitioner in the taxable years. * * *”
    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.