Sacks’s Empirical Analysis
Citation profile
3 federal appellate · 3 district ·
How this case has been cited
Cited by 36 later decisions — most recently November 2022 · most notably Jade Trading, LLC ex rel. Ervin Capital, LLC v. United States (2007), 136 F. Supp. 2d 762 - American Electric Power, Inc. v. United States (2001)
3 federal appellate · 3 district ·
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 Gregory v. Helvering · Frank Lyon Co. v. United States · Commissioner v. Brown · Cabell v. Markham · Rice's Toyota World, Inc. 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It has long been the law that a transaction with no economic effects, in which the underlying documents are a device to conceal its true purpose, does not control the incidence of taxes.”
2 later decisions quote this exact passage · from the majority“transaction had any economic substance other than creation of tax benefits.”
1 later decision quote this exact passage · from the concurrencee.g. Reddam v. Comm'r“underlying factual determinations are reviewed for clear error”
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.