Prashker v. Commissioner’s Empirical Analysis
1972
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 28 later decisions — most recently November 2018 · most notably Brown v. Commissioner of Internal Revenue (1983), Hitchins v. Commissioner (1994)
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 William H. Perry and Marian E. Perry v. Commissioner of Internal Revenue · Perry v. Commissioner · Herbert's Estate v. Commissioner · Emporium Capwell Co. v. Anglim · Byrne v. Commissioner of Internal Revenue
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he key question is whether or not the debt of the corporation runs 'directly to the shareholder'”
3 later decisions quote this exact passage · from the majority“a shareholder could borrow the money personally and then loan the money to the corporation. In that event the corporation's debt would run directly to the shareholder”
2 later decisions quote this exact passage · from the majority“Clearly there must be a debt running directly to the shareholder in order to permit the deduction from income of a corporate net operating loss.”
1 later decision quote this exact passage · from the majoritye.g. Messina v. Comm'r
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.