Cottage Savings Association v. Commissioner of Internal Revenue’s Empirical Analysis
1991
Citation profile
156 federal appellate · 15 district · 13 state decisions
How this case has been cited
Cited by 438 later decisions (23 by the Supreme Court) — most recently June 2024 · most notably Johnson v. Home State Bank (1991), Michael Wayne Williams v. John Taylor Warden (2000)
156 federal appellate · 15 district · 13 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.
Appellate journey
reviewedCottage Savings Ass'n v. Commissioner (from Sixth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1001 · 26 U.S.C. § 1031 · 26 U.S.C. § 165 · 26 U.S.C. § 7805
Relies on Udall v. Tallman · Pierce v. Underwood · Cannon v. University of Chicago · Lorillard v. Pons · Helvering v. Horst
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 438 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e must defer to [the Commissioner's] regulatory interpretations of the Code so long as they are reasonable.”
10 later decisions quote this exact passage · from the majority“agency's steady interpretation of its own 61-year-old regulation implementing a 62-year-old statute. `Treasury regulations and interpretations long continued without substantial change, applying to unamended or substantially reenacted statutes, are deemed to have received congressional approval and have the effect of law.'”
7 later decisions quote this exact passage · from the majority“defers the tax consequences of a gain or loss in property value until the taxpayer ‘realizes’ the gain or loss. The realization requirement is implicit in § 1001(a) of the Code, which defines ‘[t]he gain [or loss] from the sale or other disposition of property’ as the difference between ‘the amount realized’ from the sale or disposition of the property and its ‘adjusted basis.’”
3 later decisions 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.