Perry v. Commissioner’s Empirical Analysis
1970
Citation profile
10 federal appellate ·
How this case has been cited
Cited by 53 later decisions — most recently April 2017 · most notably Morris G. Underwood and Jackie Underwood, Individuals v. Commissioner of Internal Revenue (1976), Selfe v. United States (1985)
10 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 Knetsch v. United States · Old Colony Co v. Commissioner of Internal Revenue · Raynor v. Commissioner · Powell v. Commissioner of Internal Revenue · Powell 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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'the taxpayer poorer in a material sense'”
4 later decisions quote this exact passage“[I]t is the payment by the guarantor of the guaranteed obligation that gives rise to indebtedness on the part of the debtor to the guarantor. The mere fact that the debtor defaults and thereby renders the guarantor liable is not sufficient. . .. The adjusted basis for indebtedness referred to in [the predecessor statute] is . . . limited to `the actual economic outlay of the shareholder.'”
2 later decisions quote this exact passage“adjusted basis of any indebtedness of the corporation to the shareholder”
2 later decisions 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.