Donald R. Campbell and Patricia A. Campbell v. Commissioner of Internal Revenue’s Empirical Analysis
1989
Citation profile
16 federal appellate ·
How this case has been cited
Cited by 43 later decisions — most recently November 2018 · most notably Smith v. Commissioner (1991), Peat Oil & Gas Assocs. v. Commissioner (1993)
16 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. § 183 · 26 U.S.C. § 46 · 26 U.S.C. § 482 · 26 U.S.C. § 6653
Relies on Engdahl v. Commissioner · Brannen v. Commissioner · Lormand v. Aries Marine Corp. · Dunn v. Commissioner · Dunn 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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An activity is engaged in for profit if the taxpayer entertained an actual and honest, even though unreasonable or unrealistic, profit objective in engaging in the activity.”
6 later decisions quote this exact passage · from the majority“(1) the manner in which the taxpayer carried on the activity; (2) the expertise of the taxpayer or his advisors; (3) the time and effort expended by the taxpayer in carrying on the activity; (4) the expectation that assets used in the activity may appreciate in value; (5) the success of the taxpayer in carrying on similar or dissimilar activities; (6) the taxpayer’s history of income or loss with respect to the activity; ■ (7) the amount of occasional profit, if any, which is earned; (8) the financial status of the taxpayer; and (9) whether the elements of personal pleasure or recreation are involved.”
5 later decisions quote this exact passage · from the dissent“In determining whether such a profit motive exists, a court must consider the objective facts and must also look to nine general factors set out in the Treasury Regulations.”
4 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.