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← 65 TC 1 - Gentile v. Commissioner

Gentile v. Commissioner’s Empirical Analysis

1975

Citation profile

36
cited by 36 later decisions
1
cited 1 times by the Supreme Court
October 2013
most recently cited

7 federal appellate ·

How this case has been cited

Cited by 36 later decisions (1 by the Supreme Court) — most recently October 2013 · most notably Commissioner of Internal Revenue v. P Groetzinger (1987), Gestrich v. Commissioner (1980)

7 federal appellate ·

28019751980199020002010decided

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 Deputy v. du Pont · Flint v. Stone Tracy Co. · Higgins v. Commissioner · Bessenyey v. Commissioner · Snow 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “he neither provided nor held himself out as a provider of any goods or services to any other person.”
    2 later decisions quote this exact passage
  2. “The Tax Court subsequently reversed itself, again in a case involving nearly identical facts, and rejected the proposition that the offering of goods or services to others was an absolute prerequisite to characterization of activities as a”
    1 later decision quote this exact passage
  3. “carrying on any trade or business, within the contemplation of Sec. 23(a) [precursor to Section 62(1) ], involves holding one's self out to others as engaged in the selling of goods or services. This the taxpayer did not do.”
    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.