Commissioner of Internal Revenue v. Kenneth H., Susan L., Fred F., and Corinne B. Van Raden’s Empirical Analysis
1981
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 35 later decisions — most recently July 2015 · most notably Lemmen v. Commissioner (1981), Seligman v. Commissioner (1985)
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. § 471
Relies on United States v. Catto · Cravens v. Commissioner · Van Raden v. Commissioner · Zaninovich v. Commissioner · Clement 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[fjirst, the expenditure must be a payment ... rather than a mere deposit; second, the prepayment must be made for a business purpose and not merely for tax avoidance; and third, the deduction of such costs in the taxable year of prepayment must not result in a material distortion of income.”
3 later decisions quote this exact passage · from the majority“) allows a full deduction in the year of prepayment where that payment creates an asset having a useful life of one year or less from the day of payment. In Zaninovich, the prepayment was for one year's rent while in Van Raden the prepayment was for the purchase of cattle feed which was consumed within one year. In the instant case, it is not entirely clear whether the”
2 later decisions quote this exact passage · from the majority“is strictly applied to allow a full deduction in the year of payment where an expenditure creates an asset having a useful life beyond the taxable year of twelve months or less, it is not applied in the same manner in the other direction. Where an expenditure creates an asset having a useful life beyond the taxable year of more than twelve months, the”
2 later decisions 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.