Dean v. Commissioner’s Empirical Analysis

1961

Citation profile

cited by 85 later decisions

February 2014

most recently cited

24 federal appellate ·

How this case has been cited

Cited by 85 later decisions — most recently February 2014 · most notably Baird v. Commissioner (1977), Joseph Lupowitz Sons, Inc. (Esther Meisler, President) v. Commissioner of Internal Revenue, Harold B. Lupowitz and Sophie Lupowitz v. Commissioner of Internal Revenue, Esther Meisler v. Commissioner of Internal Revenue (1974)

24 federal appellate ·

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. § 542

Relies on Board of Assessors of the Parish of Orleans v. New York Life Insurance Company · Louis Greenspon v. Commissioner of Internal Revenue, (Three Cases). Anna Greenspon v. Commissioner of Internal Revenue · Greenspon v. Commissioner · D. Loveman & Son Export Corp. v. Commissioner · Rodgers Dairy Co. 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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“an interest-free loan results in no taxable gain to the borrower”
4 later decisions quote this exact passage · from the majority
e.g. Estate of Liechtung v. Commissioner · Baker v. Commissioner
“incurred to purchase or carry obligations the interest on which is wholly exempt from taxes”
3 later decisions quote this exact passage · from the concurrence
e.g. William G. And Martha C. Martin v. Commissioner of Internal Revenue, Joseph and Evelyn Creel v. Commissioner of Internal Revenue, Jonnie Parkinson v. Commissioner of Internal Revenue, Max Zager and Goldie R. Zager v. Commissioner of Internal Revenue · Martin v. Commissioner
“Insurance policy loans are unique because the borrower assumes no personal liability to repay the principal or to pay interest on the amount borrowed. Such loans are based on the reserve value of the insurance policies involved. If either the principal or the interest is not repaid, it is merely deducted from the reserve value of the policy. [Dean v. Commissioner, 35 T.C. 1083,1085 (1961).]”
1 later decision quote this exact passage
e.g. Cameron 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.