Booth v. Commissioner’s Empirical Analysis

Citation profile

2 federal appellate ·

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

1. “The regulations refer to a new position or substantial advancement in position and not to a new profession. The facts of this case show that petitioner’s education in the law of taxation was undertaken primarily for the purpose of becoming a partner in Wright, long & Booth which was for him a new position even though he continued to engage in his same profession, the practice of law. Under the Commissioner’s regulations, on which both parties rely, the expenses incurred are not deductible. Cf. Robert M. Kamins, 25 T.C. 1238 (1956), and Arnold Namrow, 33 T.C. 419 (1959), * * *”

   1 later decision quote this exact passage
   e.g. Furner v. Comm'r

2. “[For] the purpose of fulfilling the general educational aspirations or other personal purposes of the taxpayer”

   1 later decision quote this exact passage
   e.g. Montgomery v. Commissioner

3. “imposed as a condition to the retention by the taxpayer of his salary, status or employment.”

   1 later decision quote this exact passage
   e.g. Aronin v. Commissioner