Strong v. Commissioner’s Empirical Analysis
1976
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 78 later decisions — most recently July 2020 · most notably Coleman v. Commissioner (1986), Hospital Corp. of America v. Commissioner (1983)
6 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 Moline Properties, Inc. v. Commissioner · Higgins v. Smith · National Carbide Corporation v. Commissioner of Internal Revenue · Burnet v. Commonwealth Improvement Co. · National Investors Corp. v. Hoey
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If the corporation was intended to, or did in fact, act in its own name with respect to property, its ownership thereof will not be disregarded.”
11 later decisions quote this exact passage · from the majority“income from property must be taxed to the corporate owner, and will not be attributed to the shareholders, unless the corporation is a purely passive dummy or is used for a tax-avoidance purpose.”
2 later decisions quote this exact passage“[h]aving set up a separate entity through which to conduct their affairs, petitioners must live with the tax consequences of that choice.”
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.