William H. Perry and Marian E. Perry v. Commissioner of Internal Revenue’s Empirical Analysis
1968
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 49 later decisions — most recently November 2017 · most notably Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal Revenue (1976), Selfe v. United States (1985)
8 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
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Duberstein D Stanton · Perry v. Commissioner · Investers Diversified Services, Inc. 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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“indebtedness of the corporation to the shareholder”
4 later decisions quote this exact passage · from the majority“(a) General rule. — A net operating loss of an electing small business corporation for any taxable year shall be allowed as a deduction from gross income of the shareholders of such corporation in the manner and to the extent set forth in this section. (b) Allowance of deduction. — Each person who is a shareholder of an electing small business corporation at any time during a taxable year of the corporation in which it has a net operating loss shall be allowed as a deduction from gross income, for his taxable year in which or with which the taxable year of the corporation ends . . ., an amount equal to his portion of the corporation’s net operating loss . (c) Determination of shareholder’s portion.— (2) Limitation. — A shareholder’s portion of the net operating loss of an electing small business corporation for any taxable year shall not exceed the sum of— (B) the adjusted basis ... of any indebtedness of the corporation to the shareholder .”
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.