Kanter v. Commissioner’s Empirical Analysis
590 F.3d 410 · 2009
Citation profile
4 federal appellate ·
Relationships
Applies 26 U.S.C. § 6231 · 26 U.S.C. § 671 · 26 U.S.C. § 674 · 26 U.S.C. § 675 · 26 U.S.C. § 704 · 26 U.S.C. § 7443A · 26 U.S.C. § 7454 · 26 U.S.C. § 7482
Relies on Anderson v. City of Bessemer City · United States v. United States Gypsum Co. · Welch v. Helvering · Parklane Hosiery Co. v. Shore · Holland v. United States
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“did not base his ruling on the fact that capital from the other partners was a material income producing factor (a test derived from Internal Revenue Code § 704(e) ); instead, he found that the partners had a good-faith intent to conduct a business enterprise.”
1 later decision quote this exact passage · from the majority“applying the test outlined in Culbertson , that the record adequately supports the * * * [trial judge's] finding that all of the claimed partners * * * were the actual partners.”
1 later decision quote this exact passage · from the majority“whether, considering all the facts[,] * * * the parties in good faith and acting with a business purpose intended to join together in the present conduct of the enterprise.”
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.