Owens v. Commissioner’s Empirical Analysis
1977
Citation profile
30 federal appellate · 4 state decisions
How this case has been cited
Cited by 74 later decisions — most recently May 2019 · most notably Packard v. Commissioner (1985), Ohio Teamsters Educational and Safety Training Trust Fund v. Commissioner of Internal Revenue (1982)
30 federal appellate · 4 state decisions
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 Welch v. Helvering · Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Moline Properties, Inc. v. Commissioner · Dobson 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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he law does not permit a taxpayer * * * to cast transactions in forms when there is no economic reality behind the use of the forms. 'The incidence of taxation depends on the substance of a transaction.'”
5 later decisions quote this exact passage · from the majority“(t)he legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted,”
3 later decisions quote this exact passage · from the majority“A given result at the end of a straight path is not made a different result because reached by following a devious path.”
2 later decisions quote this exact passage · from the dissent
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.