Bobby E. Welch and Kathleen Newman v. Commissioner of Internal Revenue’s Empirical Analysis
2000
Citation profile
How this case has been cited
Cited by 56 later decisions — most recently June 2020 · most notably Calloway v. Commissioner (2010), Cadle Co. v. King (In Re King) (2002)
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
Relies on Clark v. Commissioner · Estate of E. W. Chism, Deceased, Clara Chism, and Clara Chism v. Commissioner of Internal Revenue · Bloom v. Ic System Inc · Frierdich v. Commissioner · Crowley 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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) whether the promise to repay is evidenced by a note or other instrument; (2) whether interest was charged; (3) whether a fixed schedule for repayments was established; (4) whether collateral was given to secure payment; (5) whether repayments were made; (6) whether the borrower had a reasonable prospect of repaying the loan and whether the lender had sufficient funds to advance the loan; and (7) whether the parties conducted themselves as if the transaction were a loan.”
13 later decisions quote this exact passage“Deposits in a taxpayer's bank account are prima facie evidence of income, and the taxpayer bears the burden of showing that the deposits were not taxable income but were derived from a nontaxable source.”
5 later decisions quote this exact passagee.g. Licha v. Comm'r · Willock v. Comm'r“general basis upon which courts may analyze a transaction”
1 later decision quote this exact passagee.g. Stanley 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.