Downer v. Commissioner’s Empirical Analysis
1967
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 27 later decisions (1 by the Supreme Court) — most recently April 1993 · most notably Markwardt v. Commissioner (1975), Commissioner v. Fink (1987)
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 Commissioner of Internal Revenue v. Duberstein D Stanton · United States v. Davis · Eskimo Pie Corp. v. Commissioner · United States v. General Shoe Corp. · Howell 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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A relationship between the stock he gives up and that he continues to hold is thus established” and he can have no loss until he disposes of the stock he retained. On the other hand, the cases seem to emphasize, possibly to avoid the implication that the transfer in a case like this was a gift, that the anticipated profit would arise from the increment in value of petitioner’s retained stock expected to result from the services to be rendered by the recipient of petitioner’s largess. This in turn suggests that the”
1 later decision quote this exact passage · from the dissent
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.