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← 165 F.2d 705 - Foran v. Commissioner

Foran v. Commissioner’s Empirical Analysis

165 F.2d 705 · 1948

Citation profile

86
cited by 86 later decisions
July 1974
most recently cited

64 federal appellate · 1 district ·

How this case has been cited

Cited by 86 later decisions — most recently July 1974 · most notably Lewis Thurston Anderson and Clyde Velma Anderson, Lewis Thurston Anderson v. Commissioner of Internal Revenue (1957), Archer v. Commissioner (1955)

64 federal appellate · 1 district ·

5801948195019601970decided

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

Applies 26 U.S.C. § 117

Relies on Pennsylvania Co v. Chamberlain · Greene v. Commissioner · Black 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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “And the desired inference is precluded for the further reason that respondent's right of recovery depends upon the existence of a particular fact which must be inferred from proven facts, and this is not permissible in the face of the positive and otherwise uncontradicted testimony of unimpeached witnesses consistent with the facts actually proved, from which testimony it affirmatively appears that the fact sought to be inferred did not exist. . . .”
    1 later decision quote this exact passage · from the majority
  2. “a party's testimony as to his intent may be rebutted by proof of circumstances which are inconsistent”
    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.