Adelson v. United States’s Empirical Analysis
342 F.2d 332 · 1965
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 16 later decisions — most recently February 1984
4 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.
Relationships
Applies 26 U.S.C. § 162
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Flowers · Hill v. Commissioner · Cross v. United States · Denny 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Assuming, as did the Tax Court, that foreign travel would be culturally broadening and therefore of benefit not only to the taxpayer individually but also to the university because of the potential increase in his teaching accomplishment, and that the taxpayer might thereby qualify for promotion, no justification for the claimed deduction as ordinary and necessary business expense appears * * * ” Den-nehy, 309 F.2d at page 150 . “We do not doubt the value, either to Adelson or to the school district, of the trip that Adelson took. The virtue of travel as part of a liberal education has long been accepted as established. Boswell’s father was not the first to recognize it when he financed his son’s grand tour. In Welch v. Helvering, supra, 290 U.S. 111, at pp. 115-116 , 54 S. Ct. at pp. 9-10, 78 L.Ed. 212 , Mr. Justice Cardozo put it this way. ‘Reputation and learning are akin to capital assets, like the good will of an old partnership. (Citation). For many, they are the only tools with which to hew a pathway to success. The money spent in acquiring them is well and wisely spent. It is not an ordinary expense of the operation of a business.’ “The only evidence in this record as to what Adelson did is the travel report that he filed on his return. It fully supports the trial judge’s conclusion that the trip was not primarily of a business nature, but primarily of a personal nature. Adelson’s activities while abroad ‘were not different from those reasonably expected of any other”
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.