Chester Sidell and Faye Sidells Commissioner of Internal Revenue’s Empirical Analysis
Citation profile
2 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 24 later decisions — most recently June 2020
2 federal appellate · 3 district · 1 state decisions
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 Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Stinson v. United States · Bowles v. Seminole Rock & Sand Co. · Keppel v. Tiffin Savings Bank · Johnson v. Watts Regulator Co.
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The conferees intend that this authority be exercised to protect the underlying purpose of the passive loss provision, i.e., preventing the sheltering of positive income sources through the use of tax losses derived from passive business activities .... Examples of where the exercise of such authority may ... be appropriate include the following ... (2) related property leases or sub-leases, with respect to property used in a business activity, that have the effect of reducing active business income and creating passive income....”
2 later decisions quote this exact passage · from the majority“An amount of the taxpayer’s gross rental activity income for the taxable year from an item of property equal to the net rental activity income for the year from that item of property is treated as not from a passive activity if the property ... [i]s rented for use in a trade or business activity ... in which the taxpayer materially participates ... for the taxable year....”
2 later decisions quote this exact passage · from the majority“which specify what constitutes an activity, material participation, or active participation for purposes of this section, * * * [and] requiring net income or gain from a limited partnership or other passive activity to be treated as not from a passive activity”
1 later decision quote this exact passage · from the majoritye.g. SHAW v. COMMISSIONER
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.