Spector v. Commissioner’s Empirical Analysis
1981
Citation profile
26 federal appellate ·
How this case has been cited
Cited by 77 later decisions — most recently August 2022 · most notably Coleman v. Commissioner (1986), Fono v. Commissioner (1982)
26 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
Applies 26 U.S.C. § 707 · 26 U.S.C. § 741
Relies on Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Commissioner of Internal Revenue v. Culbertson · Higgins v. Smith · Commissioner of Internal Revenue v. National Alfalfa Dehydrating and Milling Company
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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“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 to the agreement would be admissible to alter that construction or to show its unenforceability because of mistake, undue influence, fraud, duress, etc.”
7 later decisions quote this exact passage · from the concurrence“while a taxpayer is free to organize his affairs as he chooses, nevertheless, once having done so, he must accept the tax consequences of his choice ... and may not enjoy the benefit of some other route he might have chosen to follow but did not.”
5 later decisions quote this exact passage · from the majority“[A]s a general rule, [the IRS] may bind a taxpayer in the form in which the taxpayer has cast the transaction.”
3 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.