Blueberry Land Co. v. Commissioner of Internal Revenue’s Empirical Analysis
361 F.2d 93 · 1966
Citation profile
18 federal appellate · 2 state decisions
How this case has been cited
Cited by 56 later decisions — most recently September 2016 · most notably Professional Services v. Commissioner (1982), Southgate Master Fund, L.L.C. ex rel. Montgomery Capital Advisors, LLC v. United States (2011)
18 federal appellate · 2 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
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Malat v. Riddell · Textile Workers Union v. Darlington Manufacturing Co.
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“superficial formalities of a transaction to determine the proper tax treatment.”
6 later decisions quote this exact passage · from the majority“each case must be decided on its own merits by examining the form and substance of the transaction and the purpose of the relevant tax provisions to determine whether recognition of the form of the transaction would defeat the statutory purpose.”
1 later decision 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.