Sparkman v. Commissioner’s Empirical Analysis
509 F.3d 1149 · 2007
Citation profile
7 federal appellate · 2 district ·
How this case has been cited
Cited by 69 later decisions — most recently June 2025 · most notably Superior Trading, LLC v. Commissioner (2013), Debruce v. Commissioner, Alabama Department of Corrections (2014)
7 federal appellate · 2 district ·
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
Applies 26 U.S.C. § 170 · 26 U.S.C. § 6001 · 26 U.S.C. § 6651 · 26 U.S.C. § 6662 · 26 U.S.C. § 6664
Relies on United States v. United States Gypsum Co. · New Colonial Ice Co. v. Helvering · Gregory v. Helvering · Cohan v. Commissioner · Commissioner of Internal Revenue v. Culbertson
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 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where the burden of production rests on a party, a court may, at its discretion, presume or infer from that party’s failure to call a witness that the testimony the witness would have offered would not favor that party.”); United States v. Pagan-Santini, 451 F.3d 258 , 267 (1st Cir.2006) (”
1 later decision quote this exact passage · from the majority“An entity without economic substance, whether a sham partnership or a sham trust, is a sham either way and hence is not recognized for federal tax law purposes.”
1 later decision quote this exact passage · from the majoritye.g. Ioane v. Comm'r
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.