Smith v. Commissioner’s Empirical Analysis
1968
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 26 later decisions — most recently July 2010 · most notably Estate of Thomas v. Commissioner (1985), Van Raden v. Commissioner (1979)
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 Oesterreich v. Commissioner of Internal Revenue · University Properties, Inc. v. Commissioner · 2554-58 Creston Corp. v. Commissioner · University Properties, Inc. v. Commissioner · Martin 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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We adhere to our view that the substance of the transaction will be considered and whether an amount paid under the designation of rental payment is a part of the purchase price of the property or is a rental payment, will be determined from the substance of the agreement in accordance with which the payment is made.”
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.