Hayden v. Commissioner’s Empirical Analysis
1989
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 25 later decisions — most recently June 2019 · most notably Sealy Power, Ltd. v. Commissioner (1995), Smith v. Commissioner (1991)
10 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 · 26 U.S.C. § 163 · 26 U.S.C. § 167 · 26 U.S.C. § 183 · 26 U.S.C. § 212
Relies on Linkletter v. Walker · Konigsberg v. State Bar of California · White v. Commissioner · Godfrey v. Commissioner of Internal Revenue · Donald R. Campbell and Patricia A. Campbell v. Commissioner of Internal Revenue
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The threshold inquiry in determining whether an activity is a trade or business or is carried on for the production of income is whether the activity is engaged in for the primary purpose and dominant hope and intent of realizing a profit.”
6 later decisions quote this exact passage · from the majority“Section 162(a) allows deductions for professional and consulting fees, and travel and other miscellaneous expenses only if they are ordinary and necessary expenses incurred in carrying on a trade or business.”
3 later decisions quote this exact passage · from the majority“Section 212 allows a deduction for such expenses only if they are paid or incurred for the production of income.”
3 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.