Boynton v. Commissioner’s Empirical Analysis
1981
Citation profile
19 federal appellate · 1 state decisions
How this case has been cited
Cited by 46 later decisions — most recently September 2011 · most notably Kirchman v. Commissioner (1989), Compaq Computer Corporation and Subsidiaries v. Commissioner of Internal Revenue (2001)
19 federal appellate · 1 state decisions
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. § 702 · 26 U.S.C. § 704
Relies on New Colonial Ice Co. v. Helvering · Gregory v. Helvering · Knetsch v. United States · Kresser 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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'substantial economic effect', i.e., whether the allocation may actually affect the dollar amount of * * * [her share] of the total partnership income or loss independently of tax consequences.”
3 later decisions quote this exact passage · from the majority““(2) [T]he allocation to a partner under the agreement of income, gain, loss, deduction, or credit (or item thereof) does not have substantial economic effect.””
3 later decisions quote this exact passage · from the majority“"§ 704. Partner’s distributive share. "(a) Effect of partnership agreement. "A partner’s distributive share of income, gain, loss, deduction, or credit shall, except as otherwise provided in this section, be determined by the partnership agreement. "(b) Distributive share determined by income or loss ratio. "A partner’s distributive share of any item of income, gain, loss, deduction, or credit shall be determined in accordance with his distributive share of taxable income or loss of the partnership, as described in section 702(a)(9), for the taxable year, if— "(1) the partnership agreement does not provide as to the partner’s distributive share of such item, or "(2) the principal purpose of any provision in the partnership agreement with respect to the partner’s distributive share of such item is the avoidance or evasion of any tax imposed by this subtitle.””
2 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.