Seligman v. Commissioner’s Empirical Analysis
1985
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 96 later decisions — most recently August 2018 · most notably Neely v. Commissioner (1985), Antonides v. Commissioner (1988)
4 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
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Lincoln Savings and Loan Association · United States v. Mississippi Chemical Corp. · Estate of Horvath v. Commissioner · Commissioner v. Transport Manufacturing & Equipment 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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“fair notice of the matters in controversy”
3 later decisions quote this exact passage“Although this Court possesses the inherent authority to sustain respondent's determination for reasons other than those assigned in his notice of deficiency ( Estate of Horvath v. Commissioner , 59 T.C. 551 , 555 (1973)) , this should not be interpreted to afford respondent carte blanche authority to assert additional bases for his disallowance of specific items at any time prior to the issuance of an opinion.”
2 later decisions quote this exact passage“Petitioners' contentions that their administrative expense payments to Manmark were scheduled during the time period that Manmark contemplated that it would be rendering most of the services and that most of Manmark's services were, in fact, rendered during the first 12 months of the 41-month computer equipment leases is not supported by the record.”
2 later decisions 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.