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← 50 TC 409 - Ashby v. Commissioner

Ashby v. Commissioner’s Empirical Analysis

1968

Citation profile

120
cited by 120 later decisions
December 2010
most recently cited

5 federal appellate ·

How this case has been cited

Cited by 120 later decisions — most recently December 2010 · most notably Sanford v. Commissioner (1968), Foster v. Comm'r (1983)

5 federal appellate ·

560196819701980199020002010decided

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

Applies 26 U.S.C. § 162

Relies on Challenge Mfg. Co. 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 120 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The Secretary or his delegate shall prescribe such regulations as he may deem necessary to carry out the purposes of this section * * *.”
    2 later decisions quote this exact passage
  2. “circumstantial evidence, such as the nature of the business activities of the taxpayer and of the person entertained, may be sufficient to corroborate the taxpayer’s statement regarding business purpose and business relationship, * * * [S. Rept. No. 1881, 87th Cong., 2d Sess., p. 174 (1962),]”
    1 later decision quote this exact passage
  3. “unless the taxpayer establishes that the facility was used primarily for the furtherance of the taxpayer's trade or business and that the item was directly related to the active conduct of such trade or business.”
    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.