Smith v. Commissioner’s Empirical Analysis
1973
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 62 later decisions — most recently June 1997 · most notably Putoma Corp. v. Commissioner (1976), Gould v. Commissioner (1975)
3 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 Parham v. Cortese · Golsen v. Commissioner · Golsen v. Commissioner · United States v. Generes · Steinhort 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 62 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in determining whether a bad debt has a 'proximate' relation to the taxpayer's trade or business, ... the proper measure is that of dominant motivation.”
1 later decision quote this exact passage“Significant motivation is not sufficient.”
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.