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← 545 F.2d 700 - King v. United States

King v. United States’s Empirical Analysis

545 F.2d 700 · 1976

Citation profile

48
cited by 48 later decisions
March 2012
most recently cited

22 federal appellate · 4 district ·

How this case has been cited

Cited by 48 later decisions — most recently March 2012 · most notably Miller v. Commissioner of Internal Revenue (1988), Polakof v. Commissioner (1987)

22 federal appellate · 4 district ·

26019761980199020002010decided

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 11 U.S.C. § 701 · 26 U.S.C. § 165 · 26 U.S.C. § 2512 · 26 U.S.C. § 4911 · 26 U.S.C. § 4912 · 28 U.S.C. § 2111

Relies on Commissioner of Internal Revenue v. South Texas Lumber Co · Helvering v. National Grocery Co. · Sanford's Estate v. Commissioner of Internal Revenue · Blasius v. United States · Commissioner v. Wemyss

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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The reason underlying the need to establish profit motivation is that the ordinary loss deduction allowed by § 165(c)(2) was not intended to extend to a transaction lacking economic substance, amounting to nothing more than a sham.”
    3 later decisions quote this exact passage · from the majority
  2. “'If the fair market value of The Colorado Corporation stock * * * is ever determined by the Internal Revenue Service to be greater or less than the fair market value determined * * * above, the purchase price shall be adjusted to the fair market value determined by the Internal Revenue Service.'”
    2 later decisions quote this exact passage · from the majority
  3. “may depend on whether the taxpayer's motive in entering into the transaction was primarily profit.”
    2 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.