Factor v. Commissioner’s Empirical Analysis
1960
Citation profile
65 federal appellate · 5 district · 3 state decisions
How this case has been cited
Cited by 141 later decisions — most recently October 2019 · most notably Bradford v. Commissioner (1986), Professional Services v. Commissioner (1982)
65 federal appellate · 5 district · 3 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
Applies 26 U.S.C. § 7482
Relies on Conley v. Gibson · Commissioner v. Sunnen · New Colonial Ice Co. v. Helvering · Gregory v. Helvering · Deputy v. du Pont
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 141 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[T]he court is not bound to accept testimony at face value even when it is uncontroverted if it is improbable, unreasonable or questionable.””
4 later decisions quote this exact passage · from the majority““[C]oneealment of assets or covering up sources of income, handling of one’s affairs to avoid making the records usual in transactions of the kind, and any conduct, the likely effect of which would be to mislead or to conceal.””
3 later decisions quote this exact passage · from the majority“Subject to review by the Supreme Court on certiorari we have exclusive and final jurisdiction to review the decisions of the Tax Court on appeal “in the same manner and to the same extent as decisions of the district courts in civil actions tried without a jury.” On such review, the findings of the Tax Court will not be disturbed unless clear error appears. And the burden is on the taxpayer to show such clear error.”
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.