Estate of Alton Bean Deceased v. Commissioner of Internal Revenue’s Empirical Analysis
Citation profile
3 federal appellate ·
Relationships
Applies 26 U.S.C. § 1012 · 26 U.S.C. § 1366 · 26 U.S.C. § 1367 · 26 U.S.C. § 465
Relies on Hopkins v. Arizona Department of Real Estate · Selfe v. United States · Estate Leavitt III III v. Commissioner of Internal Revenue · Brown v. Commissioner of Internal Revenue · Hitchins 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Once chosen, the taxpayers are bound by the consequences of the transaction as structured, even if hindsight reveals a more favorable tax treatment.”
3 later decisions quote this exact passage“No basis is created for a shareholder, however, when funds are advanced to an S corporation by a separate entity, even one closely related to the shareholder.”
1 later decision quote this exact passagee.g. OREN v. COMMISSIONER“a mere guaranty of a corporate loan is insufficient”
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.