Miller v. Commissioner’s Empirical Analysis
1938
Citation profile
3 federal appellate · 1 district ·
How this case has been cited
Cited by 28 later decisions — most recently September 2003 · most notably Dinardo v. Commissioner (1954), Snow v. Commissioner (1958)
3 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
Relies on Welch v. Helvering · First Nat'l Bank v. Commissioner · Louisiana Jockey Club, Inc. 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“expenditures made to protect or to promote a taxpayer's business, and which do not result in the acquisition of a capital asset, are deductible”
2 later decisions quote this exact passage“In Welch v. Helvering, * * * cited in respondent’s brief, the taxpayer paid portions of the claims of former customers of a bankrupt corporation, of which he had been secretary, in order to strengthen his individual standing and credit, and to reestablish business relations with the corporation’s former customers. The Court held that such expenditures were not deductible as ordinary and necessary business expenses. The present proceeding, in our opinion, does not come within the doctrine of the Welch case. There the expenditures were made to acquire, and not to retain or protect and promote the taxpayer’s business. * * *”
1 later decision quote this exact passage“Many expenditures made without legal compulsion are deductible, such as insurance premiums on business property, bonuses to a taxpayer's employees, donations resulting in business benefits, and numerous others.”
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.