Stemkowski v. Commissioner’s Empirical Analysis
1981
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 39 later decisions — most recently August 2020 · most notably Casanova Co. v. Commissioner (1986), Stemkowski v. Commissioner (1982)
6 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 Cohan v. Commissioner · Commissioner of Internal Revenue v. Flowers · Gotthelf v. Commissioner · Byrne v. Karalexis · William F. Sanford v. Commissioner of Internal Revenue
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Player further agrees, (a) to report to the Club training camp at the time and place fixed by the Club, in good physical condition, (b) to keep himself in good physical condition at all times during the season, (c) to give his best services and loyalty to the Club and to play hockey only for the Club unless his contract is released, assigned, exchanged or loaned by the Club, (d) to co-operate with the Club and participate in any and all promotional activities of the Club and the League which will in the opinion of the Club promote the welfare of the Club or professional hockey generally, (e) to conduct himself on and off the rink according to the highest standards of honesty, morality, fair play and sportsmanship, and to refrain from conduct detrimental to the best interests of the Club, the League or professional hockey generally.”
1 later decision quote this exact passage“no accurate allocation or segregation of compensation for labor or personal services performed in the United States can be made, or when such labor or service is performed partly within and partly without the United States, the amount to be included in the gross income shall be determined by an apportionment on the time basis; that is, there shall be included in the gross income an amount which bears the same relation to the total compensation as the number of days of performance of the labor or services within the United States bears to the total number of days of performance of labor or services for which the payment is made.”
1 later decision quote this exact passage“traveling expenses under sections 62 and 162; and 7 4. Whether petitioners are entitled to deduct various miscellaneous expenses and, if so, whether they have adequately substantiated such expenses claimed for the taxable year 1971. 8 The relevant and material facts are fully and clearly set forth by Judge Oakes and Judge Goffe and need not be repeated herein. 9 * The following claims by Hanna raise issues specifically dealt with by Judge Oakes in Stemkowski : 10 Deductions for-- 11 1. living expenses in the United States. 12 2. promotional expenses for”
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.