Knetsch v. United States’s Empirical Analysis
348 F.2d 932 · 1965
Citation profile
17 federal appellate · 1 district ·
How this case has been cited
Cited by 66 later decisions — most recently November 2006 · most notably Miller v. Commissioner of Internal Revenue (1988), Davis v. Commissioner (1976)
17 federal appellate · 1 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. § 212 · 26 U.S.C. § 23 · 26 U.S.C. § 7805
Relies on Gregory v. Helvering · Helvering v. National Grocery Co. · Knetsch v. United States · United States v. Gilmore · Dixon v. Unied States
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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“and holding: 21 Insofar as the taxpayers' contention is that there is prejudicial discrimination because of a difference in treatment in favor of those who received and relied upon private rulings issued to them as against the instant taxpayers who neither applied for, nor received, a ruling of their own but relied solely on the private ruling issued to other taxpayers, we think there is no merit to such a contention. 22 Id. at 940 & n. 14; see also Bornstein, 345 F.2d at 564 n. 2 (”
2 later decisions quote this exact passage“cannot embrace profit seeking activity in which the only economic gain derived therefrom results from a tax reduction. In other words, there can be no deductible loss allowed under section 165(c)(2) if the transaction which gave rise to the loss has been determined to have been 1578”
2 later decisions quote this exact passage“The Supreme Court has said that the determinative question is whether the taxpayer’s purpose in entering into the transaction was primarily for profit. Helvering v. National Grocery Co. * * * s}c * sfc * * s}c * It appears that the dominant intent or motive here was the tax advantage sought to be derived from the deductibility of the purported interest. A secondary purpose would be that the taxpayers in purchasing these annuity contracts intended to provide for retirement income. * * * [348 F.2d at OSO-OS?.]”
1 later decision quote this exact passagee.g. Fox 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.