Canelo v. Commissioner’s Empirical Analysis
1969
Citation profile
5 federal appellate ·
How this case has been cited
Cited by 53 later decisions — most recently May 2020 · most notably Southern Pacific Transp. Co. v. Commissioner (1980), Adolph B. Canelo III and Sally M. Canelo v. Commissioner of Internal Revenue, Thomas J. Kane, Jr., and Kathryn H. Kane v. Commissioner of Internal Revenue (1971)
5 federal appellate ·
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 Cree v. Goldstein · Dobson v. Commissioner · Southern Railway Co. v. North Carolina · Herron v. State Farm Mutual Insurance · Bornstein v. United States
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'where a taxpayer makes expenditures under an agreement that he will be reimbursed therefor, such expenditures are in the nature of loans or advancements and are not deductible as business expenses.'”
4 later decisions quote this exact passage“We realize that petitioners herein have received a windfall through the improper deductions. But the statute of limitations requires eventual repose. The “tax benefit” rule disturbs that repose only if respondent [the Commissioner] had no cause to question the initial deduction, that is, if the deduction was proper at the time it was taken. Here the deduction was improper, and respondent should have challenged it before the years prior to 1960 were closed by the statute of limitations.”
2 later decisions quote this exact passage“(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....”
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.