Groetzinger v. Commissioner’s Empirical Analysis
1985
Citation profile
10 federal appellate · 3 district ·
How this case has been cited
Cited by 46 later decisions (1 by the Supreme Court) — most recently July 2019 · most notably Commissioner of Internal Revenue v. P Groetzinger (1987), Bokum v. Commissioner (1990)
10 federal appellate · 3 district ·
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.
Appellate journey
Relationships
Applies 26 U.S.C. § 162 · 26 U.S.C. § 165 · 26 U.S.C. § 174 · 26 U.S.C. § 262 · 26 U.S.C. § 55 · 26 U.S.C. § 56 · 26 U.S.C. § 62 · 26 U.S.C. § 63
Relies on Deputy v. du Pont · Glidden Company v. Zdanok Et Al. · Higgins v. Commissioner · Hildebrand v. Social Security Administration · United States v. Generes
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The fact that one person has accumulated more wealth than another ... so that passive investment may command substantially more of the wealthier person's time and attention than that of a poorer counterpart, would not justify allowing the wealthier taxpayer the benefit of trade or business treatment....”
2 later decisions quote this exact passage · from the majority“The determination of what constitutes a “trade or business” under the various provisions of the Internal Revenue Code has proven to be most difficult and troublesome over the years. Although the term appears frequently in numerous provisions of the Code it has not been defined by either the Code or the Treasury regulations nor has any authoritative judicial definition of the terms evolved.”
1 later decision quote this exact passage“The Supreme Court also has ruled that the term does not encompass purely 'personal' activities no matter how 'continuous' or 'extended' the activity may be nor how profitable . . . .”
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.