Sala v. United States’s Empirical Analysis
613 F.3d 1249 · 2010
Citation profile
3 federal appellate · 1 district ·
Appellate journey
Relationships
Applies 26 U.S.C. § 165 · 26 U.S.C. § 705 · 26 U.S.C. § 732 · 28 U.S.C. § 1291
Relies on Frank Lyon Co. v. United States · Coltec Industries, Inc. v. United States · Rogers v. United States · Black Decker Corporation v. United States · Jackson 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The existence of some potential profit is 'insufficient to impute substance into an otherwise sham transaction' where a 'common-sense examination of the evidence as a whole' indicates the transaction lacked economic substance.”
2 later decisions quote this exact passage · from the majority“correlation of losses to tax needs coupled with a general indifference to, or absence of, economic profits may reflect a lack of economic substance.”
1 later decision quote this exact passage · from the majoritye.g. Blum v. Comm'r“'the economic realities of [the] transaction * * * [were] insignificant in relation to the tax benefits of the transaction'”
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.