Sidell v. Commissioner’s Empirical Analysis
1999
Citation profile
2 federal appellate ·
Relationships
Applies 5 U.S.C. § 553 (Administrative Procedure Act of 1946)
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Commissioner of Internal Revenue v. South Texas Lumber Co · National Muffler Dealers Assn., Inc. v. United States · Dresser Industries, Inc. v. Commissioner · Schwalbach 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A taxpayer's activities include those conducted through C corporations that are subject to section 469, S corporations, and partnerships.”
1 later decision quote this exact passage“[T]he Secretary did not intend in those proposed regulations to adhere to the position previously taken in the temporary regulations.”
1 later decision quote this exact passage“nothing in the [proposed regulations] that would lead [the court] to believe that the Commissioner was proposing to retain the rule”
1 later decision quote this exact passage
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.