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← 50 TC 247 - Thoms v. Commissioner

Thoms v. Commissioner’s Empirical Analysis

1968

Citation profile

25
cited by 25 later decisions
September 1991
most recently cited

6 federal appellate ·

How this case has been cited

Cited by 25 later decisions — most recently September 1991 · most notably Houston Chronicle Publishing Co. v. United States (1973), Marsh & McLennan, Inc. v. Commissioner (1969)

6 federal appellate ·

1101968197019801990decided

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 In Re the Accounting of Brown · Commissioner v. Killian · Thrifticheck Service Corp. v. Commissioner · 9 Wash. 2d 45 - J. L. Cooper & Co. v. Anchor Securities Co. · Thrifticheck Service Corp. 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “No allowance will be permitted [for intangible capital assets] merely because, in the unsupported opinion of the taxpayer, the intangible asset has a limited useful life.”
    2 later decisions quote this exact passage
  2. “a covenant (not to compete) has the function primarily of assuring the purchaser the beneficial enjoyment of the goodwill and the seller's list of expirations.”
    2 later decisions 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.