Krukowski v. Commissioner’s Empirical Analysis

Citation profile

7 federal appellate · 1 state decisions

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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(6) Property rented to a nonpassive activity. — 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) Is rented for use in a trade or business activity * * * in which the taxpayer materially participates (within the meaning of sec.l.469-5T) for the taxable year * * *”

   6 later decisions quote this exact passage · from the majority
   e.g. Beecher v. Commissioner · Dirico v. Comm'r

2. “The term 'passive activity’ means any activity — (A) which involves the conduct of any trade or business, and (B) in which the taxpayer does not materially participate.” I.R.C. § 469(c)(1). 5 .”

   3 later decisions quote this exact passage · from the majority
   e.g. Beecher v. Commissioner · Gary Beecher Delores Beecher v. Commissioner of Internal Revenue

3. “specify what constitutes an activity, material participation, or active participation”

   3 later decisions quote this exact passage · from the majority
   e.g. Williams v. Comm'r · Syed v. Comm'r