Callaway v. Commissioner’s Empirical Analysis
2000
Citation profile
30 federal appellate · 6 district ·
How this case has been cited
Cited by 78 later decisions — most recently August 2022 · most notably Chai v. Commissioner (2017), In Re: Vytautas Vebeliunas (2003)
30 federal appellate · 6 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. § 213 · 26 U.S.C. § 6013 · 26 U.S.C. § 6031 · 26 U.S.C. § 6211 · 26 U.S.C. § 6212 · 26 U.S.C. § 6214 · 26 U.S.C. § 6216 · 26 U.S.C. § 6221
Relies on Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · Immigration & Naturalization Service v. Cardoza-Fonseca · Auer v. Robbins · Bowen v. Georgetown University Hospital · Bowles v. Seminole Rock & Sand 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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“partnership item” is statutorily defined as: any item required to be taken into account for the partnership's taxable year under any provision of subtitle A to the extent regulations prescribed by the Secretary provide that, for purposes of this subtitle, such item is more appropriately determined at the partnership level than at the partner level. IRC § 6231(a)(3); see id. § 6231(a)(4) (defining”
2 later decisions quote this exact passage · from the majority“a single unified procedure for determining the tax treatment of all partnership items at the partnership level, rather than separately at the partner level.”
2 later decisions quote this exact passage · from the majority“[e]xcept as otherwise provided in this subchapter, the tax treatment of any partnership item ... shall be determined at the partnership level.”
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.