Harris v. Commissioner’s Empirical Analysis
1974
Citation profile
5 federal appellate ·
How this case has been cited
Cited by 35 later decisions — most recently October 2017 · most notably Gulfstream Land & Development Corp. v. Commissioner (1979), Petaluma FX Partners, LLC v. Comm'r (2008)
5 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 Gagnon v. Scarpelli · Messing v. Commissioner · Foxman v. Commissioner · Foxman v. Commissioner of Internal Revenue · Crenshaw 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a searching analysis of the facts to see whether the true substance of the transaction is different from its form or whether the form reflects what actually happened.”
3 later decisions quote this exact passage““[Tjhe loss allocated to him [the plaintiff] was applied to reduce his capital account, and his share of the related items of future profits, losses, and proceeds in case of liquidation was reduced proportionately. Such an economic impact sharply distinguishes the instant situation from that which obtained in Stanley C. Orrisch * * *.””
2 later decisions quote this exact passage · from the majority“Under normal accounting procedures, if the building were sold at a gain less than the amount of such disparity petitioners would either be required to contribute to the partnership a sum equal to the remaining deficit in their capital account after the gain on the sale had been added back or would be entitled to receive a proportionately smaller share of the partnership assets on liquidation. Based on the record as a whole, we do not think that the partners ever agreed to such an arrangement.... That being true, the special allocation does not “actually affect the dollar amount of the partners’ share of the total partnership income or loss independently of tax consequences” within the meaning of the regulation”
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.