green
Positive treatment
10.7 score
Treatment trajectory · 1965 → 2026 · click a year to view as-of
1965
1995
2026
Top citers, strongest first. 30 distinct citers.
How cited ↗
cited
Cited as authority (rule)
Noyce v. Commissioner
Richmond Television Corp. v. United States , 345 F.2d 901 (4th Cir. 1965) , vacated and remanded on other issues 382 U.S. 6886 S. Ct. 233, 15 L.
cited
Cited "see"
Tondalaya Gamble & Ronald Jamison
See Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir. 1965), vacated and remanded on other grounds, 382 U.S. 68 (1965).
cited
Cited "see"
Fisher v. Comm'r
See Richmond Television Corp. v. United States , 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other grounds , 382 U.S. 68 (1965) .
examined
Cited "see"
Griggs v. Comm'r
(3×)
See Richmond Television Corp. v. United States , 345 F.2d 901 (4th Cir. 1965) , vacated and remanded on other *18 grounds , 382 U.S. 68 , 86 S. Ct. 233 , 15 L.
cited
Cited "see"
Stromatt v. Comm'r
See Richmond Television Corp. v. United States, 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded per curiam on other grounds 382 U.S. 68 (1965) .
cited
Cited "see"
Stenslet v. Comm'r
See Richmond Television Corp. v. United States, 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other grounds 382 U.S. 68 (1965) .
cited
Cited "see"
William J. Walsh Lois M. Walsh v. Commissioner of Internal Revenue
See Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir.1965), vacated on other grounds, 382 U.S. 68 (1965) (per curiam).
cited
Cited "see"
Wilkison v. Commissioner
See Richmond Television Corp. v. United States, 345 F.2d 901 , 907 (4th Cir. 1965) , remanded on another issue 382 U.S. 68 (1965) .
discussed
Cited "see"
Larsen v. Commissioner
(2×)
See Richmond Television Corp. v. United States , 345 F.2d 901 (4th Cir. 1965) , affd. per curiam 382 U.S. 68 (1965) .
examined
Cited "see"
Central Texas Savings & Loan Association v. United States
(3×)
See Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir.), vacated on other grounds, 382 U.S. 68 , 86 S.Ct. 233 , 15 L.Ed.2d 143 (1965).
discussed
Cited "see"
Haskins v. Commissioner
In support of its position, the Government relies upon a well-established line of cases holding that *22 "carrying on" a business means, in effect, "the beginning of actual business operations", Goodwin v. Commissioner, 75 T.C. 424 , 433 (1980) ; see Richmond Television Corp. v. United States, 345 F.2d 901 , 905 et seq. (4th Cir. 1965), vacated and remanded on other grounds, 382 U.S. 68 (1965) ; Bennett Paper Corp. v. Commissioner, 78 T.C. 458 , 463 (1982) ; Estate of Boyd v. Commissioner, 76 T.C. 646 , 666 (1981) .
discussed
Cited "see"
Brannen v. Commissioner
(2×)
See Richmond Television Corp. v. United States, 345 F.2d 901, 909 (4th Cir. 1965), remanded on other grounds 382 U.S. 68 (1965).
discussed
Cited "see"
Goodwin v. Commissioner
(2×)
See Richmond Television Corp. v. United States , 345 F.2d 901 (4th Cir. 1965) , vacated on other grounds, 382 U.S. 68 . * * * MGE argues that this holding elevates form over substance in that even if the operating arrangement is technically a tax partnership, the claimed expenses were in actuality simply ordinary and necessary expenses of expanding its existing business.
examined
Cited "see"
Madison Gas and Electric Company v. Commissioner of Internal Revenue
(3×)
See Richmond Television Corp. v. United States, 345 F.2d 901 (4th Cir. 1965), vacated on other grounds, 382 U.S. 68 , 86 S.Ct. 233 , 15 L.Ed.2d 143 .
cited
Cited "see"
Brown v. Commissioner
See Richmond Television Corporation v. United States, 345 F.2d 901 (4th Cir. 1965) , vacated on other grounds 382 U.S. 68 (1965) , and cases cited therein.
discussed
Cited "see"
Francis v. Commissioner
See Richmond Television Corp. v. United States, 345 F.2d 901 (4th Cir. 1965) , vacated and remanded on other grounds per curiam, 382 U.S. 68 (1965) , on remand 354 F.2d 410 (4th Cir. 1965) . *280 However, it is clear that by June of 1973, petitioner was in the trade or business of operating a rental apartment complex.
discussed
Cited "see"
Preseault v. Commissioner
See Richmond Television Corporation v. United States, 345 F. 2d 901 (C.A. 4, 1965) vacated and remanded on other grounds per curiam 382 U.S. 68 (1965) , on remand 354 F. 2d 410 (C.A. 4, 1965); Patrick L.
examined
Cited "see"
Kanofsky
(3×)
See Richmond Television Corp. v. United States, 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other issues 382 U.S. 68 , 86 S. Ct. 233 , 15 L.
cited
Cited "see, e.g."
Kwaku Eason & Ashley L. Leisner
See § 195(a); see also Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir. 1965), vacated and remanded per curiam on other grounds, 382 U.S. 68 (1965).
cited
Cited "see, e.g."
Albert & Nai-Fen Chen v. Commissioner
See sec. 195; see also Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir. 1965), vacated and remanded on other issues, 382 U.S. 68 (1965).
cited
Cited "see, e.g."
Chen v. Comm'r
See sec. 195; see also Richmond Television Corp. v. United States , 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other issues , 382 U.S. 68 (1965) .
cited
Cited "see, e.g."
Albert & Nai-Fen Chen v. Commissioner
See sec. 195; see also Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir. 1965), vacated and remanded on other issues, 382 U.S. 68 (1965).
discussed
Cited "see, e.g."
Koenig v. Commissioner
Memo. 1973-15 ("the ability to transact business does not satisfy the 'carrying on' requirement of section 162 "); see also Richmond Television Corp. v. United States, 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded per curiam on other grounds 382 U.S. 68 (1965) .
discussed
Cited "see, e.g."
Zards v. Commissioner
See, e.g, Richmond Television Corp. v. United States , 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other issues 382 U.S. 68 (1965) , original holding on this issue reaffd. *513 354 F.2d 410 , 411 (4th Cir. 1965) , overruled on other grounds NCNB Corp. v. United States , 684 F.2d 285 , 289 (4th Cir. 1982) ; Hardy v. Commissioner , 93 T.C. 684 , 687-688 (1989) ; Jackson v. Commissioner , 86 T.C. 492 , 514 (1986) .
discussed
Cited "see, e.g."
Gundotra v. Commissioner
See, e.g., Richmond Television Corp. v. United States , 345 F.2d 901 , 907 (4th Cir. 1965) , vacated and remanded on other issues 382 U.S. 68 (1965) , original holding on this issue reaffd. 354 F.2d 410 , 411 (4th Cir. 1965) , overruled on other grounds NCNB Corp. v. United States , 684 F.2d 285 , 289 (4th Cir. 1982) ; Hardy v. Commissioner , 93 T.C. 684 , 687 ↩ (1989) , affd. in part and remanded in part on another issue per order (10th Cir., Oct. 29, 1990). 26.
discussed
Cited "see, e.g."
Bendetovitch v. Commissioner
Compare Richmond Television Corp. v. United States , 345 F.2d 901 (4th Cir. 1965) , vacated and remanded on other grounds 382 U.S. 68 (1965) ; Bennett Paper Corp. v. Commissioner , 78 T.C. 458 (1982) , affd. 699 F.2d 450 (8th Cir. 1983) .
examined
Cited "see, e.g."
Seligman v. Commissioner
(3×)
See e.g., Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir.1965), vacated on other grounds, 382 U.S. 68 , 86 S.Ct. 233 , 15 L.Ed.2d 143 (1965), original holding on this issue reaffirmed, 354 F.2d 410 (4th Cir.1965), overruled in relevant part, NCNR Corp. v. United States, 684 F.2d 285, 289 (4th Cir.1982).
examined
Cited "see, e.g."
Milton J. Seligman and Estate of Francine Seligman v. Commissioner of Internal Revenue, Faye S. Hutton and Estate of C. Herbert Hutton, Deceased, Faye S. Hutton v. Commissioner of Internal Revenue
(3×)
See e.g., Richmond Television Corp. v. United States, 345 F.2d 901, 907 (4th Cir.1965), vacated on other grounds, 382 U.S. 68 , 86 S.Ct. 233 , 15 L.Ed.2d 143 (1965), original holding on this issue reaffirmed, 354 F.2d 410 (4th Cir.1965), overruled in relevant part, NCNR Corp. v. United States, 684 F.2d 285, 289 (4th Cir.1982). 19 In its opinion in Lincoln Savings & Loan Association, the Supreme Court rejected the "one year rule of thumb" approach as an exclusive and determinative method for characterizing an asset.
discussed
Cited "see, e.g."
Todd v. Commissioner
(2×)
See also Richmond Television Corp. v. United States, 345 F.2d 901 (4th Cir. 1965), vacated and remanded on other issues 382 U.S. 68 (1965).
cited
Cited "see, e.g."
Malmstedt v. Commissioner
See also Richmond Television Corporation v. United States, 345 F. 2d 901 (4th Cir. 1965) , remanded on another issue 382 U.S. 68 (1965) .
Retrieving the full opinion text from the archive…
Richmond Television Corp.
v.
United States
v.
United States
420.
Supreme Court of the United States.
Nov 15, 1965.
Robert T. Barton, Jr., for petitioner., Solicitor General Marshall and Acting Assistant Attorney General Roberts for the United States.
Per Curiam.
Cited by 165 opinions | Published
Per Curiam.
The petition for writ of certiorari is granted. In the light of the representations of the Solicitor General, and an independent examination of the record, we believe . that the Court of Appeals for the Fourth Circuit was mistaken in its view that the petitioner’s amortization claims for the taxable years 1956 and 1957 were not properly before it. Although the record is not free from ambiguity, we take the Court of Appeals to have based its decision on the ground that the petitioner’s amortization claims derived solely from net operating loss deductions carried forward from prior years, and that no additional amortization deductions for 1956 and 1957 were sought. Since we find that the petitioner adequately presented its amortization claims for 1956 and 1957, we vacate the judgment of the Court of Appeals and remand the case to .that court for the consideration of those claims, without intimation of any kind as to their merit.