Reed v. Commissioner’s Empirical Analysis
1970
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 48 later decisions — most recently October 2008 · most notably Luman v. Commissioner (1982), Professional Services v. Commissioner (1982)
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 United States v. Gilmore · Bingham's Trust v. Commissioner of Internal Revenue · Woodward v. Commissioner · Moore v. Mead's Fine Bread Co. · Penn v. Rinaldi
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.
“In our view the Supreme Court’s holding in Woodward [v. Commissioner of Internal Revenue, 397 U.S. 572 , 575, 90 S.Ct. 1302 , 25 L.Ed.2d 577 (1970)], requires us to apply the origin-of-the-claim test to the expenses arising out of the first cause of action in Reed v. Robilio [ 248 F.Supp. 602 (W.D.Tenn.1965)]. This, in turn, requires a decision for the respondent. In that first cause of action the petitioners were attempting to obtain title to the 30.66-percent interest in R & C. The complaint filed on behalf of Martha [Reed] with the District Court sought an order of reconveyance. It is manifest that this would require a conveyance of title to the interest. Not only was “the origin of the claim litigated * * * in the process of acquisition itself,” but the litigation was a direct attempt to acquire. Woodward v. Commissioner of Internal Revenue, supra, 397 U.S. at 577 , 90 S.Ct. 1302 . [Emphasis supplied.]”
4 later decisions quote this exact passage · from the majority“test has no application here. That uncertain and difficult test may be the best that can be devised to determine the tax treatment of costs incurred in litigation that may affect a taxpayer's title to property more or less indirectly, and that thus calls for a judgment whether the taxpayer can fairly be said to be”
1 later decision quote this exact passage · from the majority“Ruoff v. Commissioner, 30 T.C. 204 , 208 (1958) .[Fn. ref. omitted.] We agree with the Tax Court and the Court of Appeals that the”
1 later decision 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.