Kelly v. Patterson’s Empirical Analysis
331 F.2d 753 · 1964
Citation profile
12 federal appellate · 1 district ·
How this case has been cited
Cited by 29 later decisions (1 by the Supreme Court) — most recently May 1984 · most notably United States v. Generes (1972), Duval v. United States (1984)
12 federal appellate · 1 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. § 166
Relies on Whipple v. Commissioner · Trent v. Commissioner · George P. Weddle and Bertha R. (Terris) Weddle v. Commissioner of Internal Revenue · United States v. Byck · Weddle 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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“bad debt. Petitioner's business was primarily that of a stylist, and was based upon his unusual talents in this field. The corporation was organized to exploit those talents. Where a stockholder-employee's loan to his corporation is made for the purpose of protecting his job, it has been recognized that the loan may be proximately related to his trade or business (as an officer or employee) and therefore may qualify as a”
1 later decision quote this exact passage · from the majority“(B) where any nonbusiness debt becomes worthless within the taxable year, the loss resulting therefrom shall be considered a loss from the sale or exchange, during the taxable year, of a capital asset held for not more than 6 months.”
1 later decision quote this exact passage · from the majority“(1) Wholly worthless debts. — There shall be allowed as a deduction any debt which becomes worthless within the taxable year. * * * * *”
1 later decision 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.