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← 598 F.2d 464 - Sonnleitner v. Commissioner

Sonnleitner v. Commissioner’s Empirical Analysis

1979

Citation profile

37
cited by 37 later decisions
1
states following
December 2015
most recently cited

18 federal appellate · 1 state decisions

How this case has been cited

Cited by 37 later decisions — most recently December 2015 · most notably Brock v. Entre Computer Centers, Inc. (1991), Spector v. Commissioner (1981)

18 federal appellate · 1 state decisions

18019791980199020002010decided

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. § 1202 · 26 U.S.C. § 7482

Relies on Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennan · Ullman v. Commissioner · Schulz v. Commissioner · Balthrope v. Commissioner of Internal Revenue · Commissioner v. Killian

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

  1. “reasonable men, genuinely concerned with their economic future, might bargain for such an agreement.”
    3 later decisions quote this exact passage · from the majority
  2. “a party can challenge the tax consequences of his agreement as construed by the Commissioner only by adducing proof which in an action between the parties would be admissible to alter that construction or to show its unenforceability because of mistake, undue influence, fraud, duress, etc.”
    2 later decisions quote this exact passage · from the majority
  3. “[w]hen the parties to a transaction . .. have specifically set out the covenants in the contract and have given them an assigned value, strong proof must be adduced by them in order to overcome that declaration.”
    2 later decisions 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.