Haley v. Commissioner’s Empirical Analysis
1953
Citation profile
19 federal appellate · 2 district ·
How this case has been cited
Cited by 39 later decisions — most recently August 2015 · most notably Podell v. Commissioner (1970), State National Bank v. United States (1975)
19 federal appellate · 2 district ·
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. § 181 · 26 U.S.C. § 182 · 26 U.S.C. § 183 · 26 U.S.C. § 23
Relies on Helvering v. Clifford · Commissioner of Internal Revenue v. Culbertson · Burnet v. Sanford & Brooks Co. · Stearns Co of Boston Mass v. United States · Helvering v. Lazarus
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Partnership. — Por purposes of this subtitle, tbe term “partnership” includes a syndicate, group, pool, joint venture or other unincorporated organization through or by means of which any business, financial operation, or venture is carried on, and which is not, within the meaning of this title [subtitle], a corporation or a trust or estate. * * * [Emphasis supplied.]]”
3 later decisions quote this exact passage · from the majority“neither local law nor the expressed intent of the parties as to the legal nature and effect of their * * * agreements are conclusive as to the existence or nonexistence of a partnership * * * for Federal tax purposes.”
2 later decisions quote this exact passage · from the majority““[A] ‘special combination of two or more persons, where in some specific venture a profit is jointly sought without any actual partnership or corporate designation!’ ””
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.