Miller v. Commissioner’s Empirical Analysis
1978
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 37 later decisions — most recently November 2007 · most notably Recklitis v. Commissioner (1988), Goodwin v. Commissioner (1980)
1 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
Applies 12 U.S.C. § 1841 (§ 2 of the Bank Holding Company Act of 1956)
Relies on Ohio Bureau of Employment Services v. Hodory · Corn Products Refining Company v. Commissioner of Internal Revenue · Oliphant v. Suquamish Indian Tribe · McIntosh v. United States · W. W. Windle Co. 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“interest paid or accrued on indebtedness incurred or continued to purchase or carry property held for investment.”
7 later decisions quote this exact passage“original purpose of [the] acquisition and the reason for continued retention are both devoid of substantial investment intent should the stock be treated otherwise.”
4 later decisions quote this exact passage“carry no more weight than a position advanced on brief by the respondent.”
3 later decisions 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.