Commissioner of Internal Revenue v. Flowers’s Empirical Analysis
326 U.S. 465 · 1946
Citation profile
576 federal appellate · 32 district · 21 state decisions
How this case has been cited
Cited by 1,830 later decisions (15 by the Supreme Court) — most recently September 2020 · most notably Anderson v. Mt. Clemens Pottery Co. (1946), United States v. Correll (1967)
576 federal appellate · 32 district · 21 state decisions
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
reviewedFlowers v. Commissioner (from Fifth Circuit Court of Appeals)
Relationships
Relies on Commissioner of Internal Revenue v. Heininger · Dobson v. Commissioner · Boehm v. Commissioner · Addison v. Holly Hill Fruit Products, Inc.
Cited together with Peurifoy v. Commissioner · Welch v. Helvering · Commissioner of Internal Revenue v. A Stidger · United States v. Correll · Deputy v. du Pont
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 1,830 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The exigencies of business rather than the personal conveniences and necessities of the traveler must be the motivating factors.”
136 later decisions quote this exact passage · from the majority“(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— (1) a reasonable allowance for salaries or other compensation for personal services actually rendered; (2) traveling expenses (including amounts expended for meals and lodging other than amounts which are lavish or extravagant under the circumstances) while away from home in the pursuit of a trade or business; and (3) rentals or other payments required to be made as a condition to the continued use or possession, for purposes of the trade or business, of property to which the taxpayer has not taken or is not taking title or in which he has no equity.”
1 later decision quote this exact passage · from the dissent
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.