Hoyt v. Commissioner’s Empirical Analysis
145 F.2d 634 · 1944
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 26 later decisions — most recently May 2005 · most notably National Carbide Corporation v. Commissioner of Internal Revenue (1949), Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal Revenue (1957)
9 federal appellate ·
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 Shiman v. Commissioner · American Cigar Co. v. Commissioner · New York Trust Co. v. Island Oil & Transport Corp. · W. F. Young, Inc. 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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But what we said in that case serves rather to sustain the Tax Court’s decision. * * * there was * * * no showing that, at the time when the guaranty was made, the brother-in-law (who was insolvent when the taxpayer was called upon to pay the broker under the guaranty) was not in such financial condition that there then was little probability that he could not repay any amount which taxpayer might later be called upon to pay the broker.”
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.