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← 108 TC 524 - Booth v. Commissioner

Booth v. Commissioner’s Empirical Analysis

1997

Citation profile

40
cited by 40 later decisions
2
states following
September 2016
most recently cited

2 federal appellate · 4 state decisions

How this case has been cited

Cited by 40 later decisions — most recently September 2016 · most notably Neonatology Assocs., P.A. v. Comm'r (2000), National Security Systems, Inc. v. Iola (2012)

2 federal appellate · 4 state decisions

200199720002010decided

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

Relies on Welch v. Helvering · Landgraf v. USI Film Products · Consumer Product Safety Commission v. GTE Sylvania, Inc. · New Colonial Ice Co. v. Helvering · United States v. American Trucking Associations

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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Although respondent is concerned that the ability of a participating employer to terminate voluntarily its participation in the * * * [plan] allows the employer to control the timing of income to its employees, we regard that concern as misplaced. Respondent’s concern could also be expressed with respect to the pension plan of a corporation owned by a single shareholder. Although the shareholder may be the only employee, it does not necessarily follow that such a pension plan provides for receipt of deferred compensation merely because the owner/shareholder has the ability to terminate the pension plan at will. [.Id.]”
    1 later decision quote this exact passage
  2. “where multiple employers have contributed funds to an independent party to hold in separate accounts until disbursed primarily for the benefit of the contributing employer's employees in accordance with unique terms established by that employer.”
    1 later decision quote this exact passage · from the concurrence
  3. “authorities underlying a legal opinion, however, may give rise to substantial authority for the tax treatment of an item.”
    1 later decision quote this exact passage · from the concurrence

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.