Robert J. And Mildred Frysinger v. Commissioner of Internal Revenue’s Empirical Analysis
1981
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 18 later decisions — most recently June 2009
2 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
Applies 26 U.S.C. § 162 · 26 U.S.C. § 446 · 26 U.S.C. § 461 · 26 U.S.C. § 464 · 26 U.S.C. § 471
Relies on Lucas v. American Code Co. · Thor Power Tool Company v. Commissioner of Internal Revenue · Commissioner v. Hansen · Harelson v. United States · Wisconsin v. Illinois
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Rather we hold that where the taxpayer is a farmer covered by the special provisions allowing farmers to take current deductions for feed expenses, where the prepayment is for a business purpose and not merely tax avoidance, and where it is in line with normal business practice and not unreasonable, the Commissioner cannot use his discretionary authority to vitiate the benefits granted the taxpayer by his own regulations merely because the taxpayer’s method may otherwise result in a distortion of income.”
2 later decisions quote this exact passage · from the majority“The distortion created by the deduction, in light of the special treatment accorded farmers by the regulations, cannot be considered controlling.”
1 later decision quote this exact passage · from the majority“principally because of the special treatment traditionally granted farmers under the tax regulations.”
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.