Whitmire v. Commissioner’s Empirical Analysis
178 F.3d 1050 · 1999
Citation profile
6 federal appellate · 1 district ·
Relationships
Applies 26 U.S.C. § 465 · 26 U.S.C. § 6501 · 26 U.S.C. § 7482
Relies on Casebeer v. Commissioner · Moser v. Commissioner · Gefen v. Commissioner · American Principals Leasing Corp. v. United States · Young 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We conclude that Whitmire was not at risk under section 465 because he was protected from loss by section 465(b)(4) guarantees, and because the scenario under which Whitmire would suffer loss was no more than a 'theoretical possibility' based on the fulfillment of remote numerous contingencies.”
1 later decision quote this exact passage · from the majoritye.g. Pack v. Comm'r
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.