Rude v. Commissioner’s Empirical Analysis
1967
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 40 later decisions — most recently May 2017 · most notably Estate of Reynolds v. Commissioner (1970), Arrigoni v. Commissioner (1980)
2 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 Van Anda v. Commissioner · Clark v. Commissioner · Carr v. Van Anda's Estate, Deceased, Paul Van Anda v. Commissioner of Internal Revenue · Dolan v. Commissioner · Mercil 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Only a bona fide debt qualifies for purposes of section 166 . A bona fide debt is a debt which arises from a debtor-creditor relationship based upon a valid and enforceable obligation to pay a fixed or determinable sum of money.”
1 later decision quote this exact passage · from the majority“the presumption being that the transfer between related parties is a gift.”
1 later decision quote this exact passage
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.