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← 172 F.3d 1311 - Olson v. United States

Olson v. United States’s Empirical Analysis

172 F.3d 1311 · 1999

Citation profile

45
cited by 45 later decisions
April 2020
most recently cited

14 federal appellate · 1 district ·

How this case has been cited

Cited by 45 later decisions — most recently April 2020 · most notably Chimblo v. Commissioner (1999), Demes v. United States (2002)

14 federal appellate · 1 district ·

2201999200020102020decided

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. § 6213 · 26 U.S.C. § 6221 · 26 U.S.C. § 6222 · 26 U.S.C. § 6231 · 26 U.S.C. § 6621 · 26 U.S.C. § 6659 · 26 U.S.C. § 701

Relies on David Muskrat v. · N.C.F. Energy Partners v. Commissioner · Woody v. Commissioner · 37 Fed. Cl. 727 - Olson v. United States

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

  1. “any item to the extent such item is affected by a partnership item.”
    5 later decisions quote this exact passage · from the majority
  2. “(3) Partnership item. — The term "partnership item” means, with respect to a partnership, any item required to be taken into account for the partnership’s taxable year under any provision of subtitle A to the extent regulations prescribed by the Secretary provide that, for purposes of this subtitle, such item is more appropriately determined at the partnership level than at the partner level.”
    4 later decisions quote this exact passage · from the majority
  3. “[g]eneral rule” that "a partnership shall be considered as terminated ... if ... within a 12-month period there is a sale or exchange of 50 percent or more of the total interest in partnership capital and profits.” 3 . Pursuant to I.R.C. §§ 754 and 743(b)(1), if a partnership files an election in accordance with regulations prescribed by the Secretary of the Treasury, the basis of partnership property is adjusted by an amount that is determined by a specified formula. 4 . A partnership itself is not liable for the payment of income taxes. See I.R.C. § 701. However, each year a partnership must file an information return (IRS Form 1065) reporting items of gross income and allowable deductions. See id. § 6031(a). The tax treatment of a partnership item, which is "any item required to be taken into account for the partnership's taxable year,” id. § 6231(a)(3), is determined at the partnership level. See id. § 6221. Partnership items then are allocated among the partners, who bear the tax consequences of them. See id. § 702. The allocation to each partner is reported on a Schedule K-l to the partnership's Form 1065 return. Each partner must report his or her distributive share of the allocated partnership items. See id. Pursuant to I.R.C. § 6222(a), partners, on their individual returns, are required "to treat partnership items consistently with the item's treatment on the partnership information return.”
    2 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.