Rosenberg v. Commissioner’s Empirical Analysis
1946
Citation profile
3
cited by 3 later decisions
February 1948
most recently cited
Relationships
Applies 26 U.S.C. § 181
Relies on Lucas v. Earl · Commissioner v. Tower · Michigan Trust Co. v. City of Grand Rapids · Greenberg v. Commissioner · Hankey v. French
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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“There can be no question that a wife and husband may, under certain circumstances, become partners for tax, as for other purposes. If she either invests capital originating with her or substantially contributes to the control and management of the business, or otherwise performs vital additional services, or does all of those things she may be a partner as contemplated by 26 U.S.C. §§ 181 , 182 . * * * But when she does not share in the management and control of the business, contributes no vital additional service, and where the husband purports in some way to have given her a partnership interest, the Tax Court may properly take these circumstances into consideration in determining whether the partnership is real within the meaning of the federal revenue laws.”
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.