Owensby & Kritikos, Inc. v. Commissioner’s Empirical Analysis
819 F.2d 1315 · 1987
Citation profile
26 federal appellate · 1 state decisions
How this case has been cited
Cited by 108 later decisions — most recently May 2023 · most notably Estate of Wallace v. Commissioner (1990), Rutter v. Commissioner (1988)
26 federal appellate · 1 state decisions
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
Relies on Anderson v. City of Bessemer City · United States v. United States Gypsum Co. · Welch v. Helvering · Barrett v. United States · Helvering v. National Grocery Co.
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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a reasonable allowance for salaries or other compensation for personal services actually rendered”
15 later decisions quote this exact passage · from the majority“test of deductibility in the case of compensation payments is whether they are reasonable and are in fact payments purely for services.”
5 later decisions quote this exact passage · from the majority“An ostensible salary paid by a corporation may be a distribution of a dividend on stock.”
5 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.