Commissioner of Internal Revenue v. A Stidger’s Empirical Analysis
1967
Citation profile
151 federal appellate · 6 district · 3 state decisions
How this case has been cited
Cited by 319 later decisions (8 by the Supreme Court) — most recently September 1996 · most notably United States v. Wade (1967), United States v. Correll (1967)
151 federal appellate · 6 district · 3 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
reviewedStidger v. Commissioner (from Ninth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 162 · 26 U.S.C. § 262 · 37 U.S.C. § 402 · 37 U.S.C. § 403 · 37 U.S.C. § 404 · 37 U.S.C. § 405 · 37 U.S.C. § 406 · 37 U.S.C. § 427
Relies on Commissioner of Internal Revenue v. Flowers · Helvering v. Winmill · Peurifoy v. Commissioner · Cockrell 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 319 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“it is the province of Congress and the Commissioner, not the courts, to make the appropriate adjustments.”
4 later decisions quote this exact passage · from the majority“(1) The expense must be a reasonable and necessary traveling expense, as that term is generally understood. This includes such items as transportation fares and food and lodging expenses incurred while traveling. (2) The expense must be incurred “while away from home.” (3) The expense must be incurred in pursuit of business. This means that there must be a direct connection between the expenditure and the carrying on of the trade or business of the taxpayer or of his employer. Moreover, such an expenditure must be necessary or appropriate to the development and pursuit of the business or trade.”
2 later decisions quote this exact passage · from the majority““Trade or Business Expenses. “(a). In General.—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, including— * * * * * * “(2) traveling expenses * * * while away from home in the pursuit of a trade of business * * (Emphasis supplied)”
2 later decisions quote this exact passage · from the dissent
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.