Greene v. United States’s Empirical Analysis
13 F.3d 577 · 1994
Citation profile
91 federal appellate · 4 district · 5 state decisions
How this case has been cited
Cited by 236 later decisions — most recently March 2025 · most notably Suez Equity Investors Lp and Sei Associates v. The Toronto-Dominion Bank (2001), Jazini v. Nissan Motor Company, Ltd. (1998)
91 federal appellate · 4 district · 5 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.
Appellate journey
reviewedthe decision below (from New York Southern District Court)
Relationships
Applies 26 U.S.C. § 1256 · 26 U.S.C. § 170 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Singleton v. Wulff · Commissioner v. Sunnen · Needler v. Valley National Bank of Arizona · Helvering v. Horst · Commissioner of Internal Revenue v. Court Holding Co
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 236 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is a well-established general rule that an appellate court will not consider an issue raised for the first time on appeal.”
12 later decisions quote this exact passage · from the majority“if the elements of the claim were fully set forth and there is no need for additional fact finding”
9 later decisions quote this exact passage · from the majority“when we think it necessary to remedy an obvious injustice.”
6 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.