Rubnitz v. Commissioner’s Empirical Analysis
1977
Citation profile
5 federal appellate ·
How this case has been cited
Cited by 46 later decisions — most recently October 2014 · most notably Crown v. Commissioner (1981), Baird v. Commissioner (1977)
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 Welch v. Helvering · Deputy v. du Pont · Eckert v. Burnet · Helvering v. Price · Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. Goodstein
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.
“a prearranged retransfer of funds, immediately after they had been deposited in [the borrower’s] account, as the final step in an integrated transaction would not constitute the “payment” which gives rise to a deduction by a cash basis taxpayer. Thomas Watson, 8 T.C. 569 , 579; T. Harvey Ferris, 38 B.T.A. 312 , 317, affirmed per curiam, 102 F.2d 985 (2d Cir.)[ 11 ]”
3 later decisions quote this exact passage“[A] cash basis borrower has not paid interest when the loan transaction is structured so that a loan fee is “withheld” by the lender from what is called the principal amount of the loan and only the supposed principal amount minus the loan fee is actually made available for the borrowing taxpayer’s use. * * * [B]y signing a promissory note, it [the borrower] specifically chose to postpone paying that amount until sometime in the future. The entire $57,780 was to be paid ratably by the borrower over the life of the loan as one component of the monthly installments * * * which would ultimately result in the payment of the full $1,650,000. Therefore, [the borrower] may not deduct the $57,750 as “interest paid” during 1970. Rubnitz, supra, at 628. 10”
2 later decisions quote this exact passage“of his liability for interest, is not thereby entitled to a deduction for”
1 later decision quote this exact passage
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.