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← 57 TC 546 - Howell v. Commissioner

Howell v. Commissioner’s Empirical Analysis

1972

Citation profile

45
cited by 45 later decisions
May 2005
most recently cited

How this case has been cited

Cited by 45 later decisions — most recently May 2005 · most notably McManus v. Commissioner (1975), Bresler v. Commissioner (1975)

2101972198019902000decided

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 26 U.S.C. § 1201

Relies on Moline Properties, Inc. v. Commissioner · Corn Products Refining Company v. Commissioner of Internal Revenue · Malat v. Riddell · Commissioner v. Gillette Motor Transport, Inc. · United States v. Ada Belle Winthrop, Individually and as Under the Will of Guy L. Winthrop, Deceased

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

  1. “(1) stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business * * *.”
    2 later decisions quote this exact passage
  2. “though the property may have been acquired with the ultimate intention of reselling, this does not result in a determination that the property was held primarily for sale in the ordinary course of business.”
    1 later decision quote this exact passage
  3. “There is nothing unique or improper about a corporation engaging in exclusively investment activity,”
    1 later decision 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.