Frankel v. Commissioner’s Empirical Analysis
1973
Citation profile
4 federal appellate · 1 district ·
How this case has been cited
Cited by 31 later decisions — most recently October 2017 · most notably Brown v. Commissioner of Internal Revenue (1983), Hitchins v. Commissioner (1994)
4 federal appellate · 1 district ·
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 United States v. Basye · Raynor v. Commissioner · William H. Perry and Marian E. Perry v. Commissioner of Internal Revenue · Perry v. Commissioner · Blum v. Commissioner
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A shareholder’s portion of the net operating loss of an electing small business corporation for any taxable year shall not exceed the sum of— (A) the adjusted basis ... of the shareholder’s stock in the electing small business corporation ... and (B) the adjusted basis ... of any indebtedness of the corporation to the shareholder. ...”
1 later decision quote this exact passage“serious detriment to the taxpayer pervades the subchapter, and without constant and expert counsel [its] 'simplicity' * * * can change into nightmarish, if not ruinous, complexity.”
1 later decision quote this exact passage“Some Intriguing Recent Developments in Subchapter S,”
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.