Nickeson v. Commissioner’s Empirical Analysis
1992
Citation profile
6 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 24 later decisions — most recently November 2022
6 federal appellate · 3 district · 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. § 174 · 26 U.S.C. § 6653
Relies on Welch v. Helvering · Higgins v. Commissioner · Ohse v. Hughes · Connecticut National Bank v. Germain · 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“must show ... that their activities were substantial and regular enough to establish that they were actively involved in the trade or business”
3 later decisions quote this exact passage · from the majority“not only to costs paid or incurred by the taxpayer for research or experimentation undertaken directly by him but also to expenditures paid or incurred for research or experimentation carried on in his behalf by another person or organization”
1 later decision quote this exact passage · from the majority“an initial inquiry into whether the activity was undertaken or continued in good faith, with the dominant hope and intent of realizing a profit, i.e., taxable income therefrom.”
1 later decision 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.