Commissioner of Internal Revenue v. F Tellier’s Empirical Analysis
1966
Citation profile
242 federal appellate · 18 district · 19 state decisions
How this case has been cited
Cited by 889 later decisions (12 by the Supreme Court) — most recently November 2021 · most notably Indopco, Inc. v. Commissioner (1992), Bob Jones University v. United States (1983)
242 federal appellate · 18 district · 19 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
reviewedTellier v. Commissioner of Internal Revenue (from Second Circuit Court of Appeals)
Relationships
Applies 15 U.S.C. § 77Q (§ 17 of the Securities Act of 1933) · 18 U.S.C. § 1341 (White-Collar Crime Penalty Enhancement Act of 2002) · 18 U.S.C. § 371 · 26 U.S.C. § 162
Relies on Gideon v. Wainwright · Welch v. Helvering · M'Culloch v. State of Maryland · Deputy v. du Pont · Commissioner of Internal Revenue v. Heininger
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 889 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“only the minimal requirement that the expense be `appropriate and helpful' for `the development of the [taxpayer's] business.'”
47 later decisions quote this exact passage · from the majority““We start with the proposition that the federal income tax is a tax on net income, not a sanction against wrongdoing. That principle has been firmly imbedded in the tax statute from the beginning. * * * ””
9 later decisions quote this exact passage · from the majority“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”
9 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.