Cagle v. Commissioner’s Empirical Analysis
1976
Citation profile
14 federal appellate · 2 state decisions
How this case has been cited
Cited by 82 later decisions — most recently April 2019 · most notably Surloff v. Commissioner (1983), Thomas v. Commissioner (1985)
14 federal appellate · 2 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.
Relationships
Applies 26 U.S.C. § 707
Relies on Deputy v. du Pont · Interstate Transit Lines v. Commissioner · Woodward v. Commissioner · Commissioner of Internal Revenue v. Idaho Power Company · Hotel Employees Local No. 255 v. Leedom
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(c) Guaranteed Payments. — To the extent determined without regard to the income of the partnership, payments to a partner for services or the use of capital shall be considered as made to one who is not a member of the partnership, but only for the purposes of section 61(a) (relating to gross income) and section 162(a) (relating to trade or business expenses).”
5 later decisions quote this exact passage · from the majority“all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business.”
5 later decisions quote this exact passage · from the majority“When, however, an expenditure is made for the acquisition of an asset the useful life of which will extend beyond the year in which cost is incurred, such expenditure is considered as a capital item, and is not generally deductible as a business expense.”
1 later decision 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.