King v. United States’s Empirical Analysis
545 F.2d 700 · 1976
Citation profile
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 ·
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.
“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 majoritye.g. Cross · Hauser v. Commissioner“'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“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.