Frederick Todd, II v. CIR’s Empirical Analysis
2012
Citation profile
2 federal appellate ·
Relationships
Applies 26 U.S.C. § 6662
Relies on Neonatology Associates Pa v. Commissioner of Internal Revenue · Neonatology Assocs., P.A. v. Comm'r · Saviano v. Commissioner · Klamath Strategic Investment Fund ex rel. St. Croix Ventures v. United States · Tomlinson v. 1661 Corp.
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Whether a certain transaction constitutes a loan for income tax purposes is a factual question involving several considerations, but a distinguishing characteristic of a loan is the intention of the parties that the money advanced be repaid.”
1 later decision quote this exact passage · from the majoritye.g. Gassaway v. Comm'r“opined on any or all of the items reported therein.”
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.