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6 canonical passages across 6 cases, quoted by 40 opinions in total. These passages cluster together because the same opinions keep quoting them side by side: they state parts of one doctrine. The anchor passage is from Zachary H. Sacks and Salley Sacks v. Commissioner of Internal Revenue.
| # | Case | Flag | Canonical passage | Citers |
|---|---|---|---|---|
| 1 | Zachary H. Sacks and Salley Sacks v. Commissioner of Internal Revenue Anchor | green | “depends upon both the legitimacy of the underlying investment, and due care in the claiming of the deduction.” | 18 |
| 2 | Freytag v. Commissioner | green | “not an absolute defense to negligence, but rather a factor to be considered.” | 9 |
| 3 | Robnett v. Commissioner | green | “merely claiming the loss, without further explanation,” | 4 |
| 4 | Waldemar Forchuk, Forchuk Management, Inc. v. Unsecured Creditors Consolidated Oversight Committee, Mosier | green | “construe this memorandum or any prior or subsequent communications as constituting legal or tax advice” | 3 |
| 5 | Utah Jojoba I Research v. Commissioner | green | “another example of efforts by promoters and investors in the early 1980's to reduce the cost of commencing and engaging in the farming of jojoba by claiming, inaccurately, that capital expenditures in jojoba plantations might be treated as research or experimental expenditures f…” | 3 |
| 6 | WELCH | green | “we hold that utah i was not actively involved in a trade or business and also lacked a realistic prospect of entering a trade or business.” | 3 |
A red or yellow flag on a member means the underlying case has negative treatment: for those, check the case page before relying on the passage.