Beck v. Commissioner’s Empirical Analysis
1985
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 269 later decisions — most recently December 2016 · most notably Antonides v. Commissioner (1988), Rose v. Commissioner (1987)
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
Relies on Welch v. Helvering · Dreicer v. Commissioner · Fruit Growers Exp. Co. v. Brotherhood Ry. Carmen of U. S. And Canada, Ry. Employees' Dept., Afl-Cio · Engdahl v. Commissioner · Brannen v. Commissioner
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 269 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an actual and honest objective of making a profit.”
12 later decisions quote this exact passage“Dreicer v. Commissioner, 78 T.C. 642 , 646 (1982) , affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983) ; Fuchs v. Commissioner, 83 T.C. 79 , 98 (1984) ; Dean v. Commissioner, 83 T.C. 56 , 74 (1984) . While a reasonable expectation of profit is not required, petitioner's objective of making a profit must be bona fide. Fox v. Commissioner, 80 T.C. 972 , 1006 (1983) , affd. * * *.”
3 later decisions quote this exact passage“Essential to such a showing is a demonstration that petitioner had “an actual and honest objective of making a profit.” Dreicer v. Commissioner, 78 T.C. 642, 646 (1982), affd. without opinion 702 F.2d 1205 (D.C. Cir. 1983); Fuchs v. Commissioner, 83 T.C. 79, 98 (1984); Dean v. Commissioner, 83 T.C. 56, 74 (1984). While a reasonable expectation of profit is not required, petitioner’s objective of making a profit must be bona fide. Fox v. Commissioner, 80 T.C. 972, 1006 (1983), affd. * * * . “Profit” in this context means economic profit, independent of tax savings. Herrick v. Commissioner, [ 85 T.C. 237, 254 (1985)]; Surloff v. Commissioner, 81 T.C. 210, 233 (1983). Whether petitioner possessed the requisite profit objective is a question of fact to be resolved on the basis of all the facts and circumstances. Elliott v. Commissioner, 84 T.C. 227, 236 (1985) [affd. 782 F.2d 1027 (3d Cir. 1986)], and cases cited therein. Although no one factor is determinative, greater weight must be given to objective facts than to petitioner’s mere statement of his intent. Siegel v. Commissioner, 78 T.C. 659, 699 (1982); Engdahl v. Commissioner, 72 T.C. 659, 666 (1979); sec. 1.183-2, Income Tax Regs. * * * [Fn. ref. omitted.]”
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.