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← 71 TC 1 - Long v. Commissioner

Long v. Commissioner’s Empirical Analysis

1978

Citation profile

27
cited by 27 later decisions
May 2012
most recently cited

4 federal appellate ·

How this case has been cited

Cited by 27 later decisions — most recently May 2012 · most notably Kornman & Associates, Inc. v. United States (2008), Marriott International Resorts, L.P. v. United States (2009)

4 federal appellate ·

9019781980199020002010decided

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 Shomaker v. Commissioner · Bolger v. Commissioner · Douglas J. v. Commissioner · Lemery v. Commissioner · Groetzinger 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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “After paying the partnership liabilities, the estate sought and obtained a determination from the probate court that Robert Long, the other general partner and a beneficiary of the estate, was responsible for his 75-percent share of those liabilities. Robert's distributive share of estate assets was then used to offset his liability for the partnership debts and other claims previously paid by the estate. Thus, although the estate advanced the cash to pay those liabilities, it did not actually carry their full burden. The record is unclear on the extent to which the estate was able to obtain from Robert, through his share of the estate assets or otherwise, his contribution towards the partnership liabilities. In this regard, the burden of proof is on petitioner. Rule 142(a), Tax Court Rules of Practice and Procedure. As the record now stands, we must conclude that the estate did receive Robert's full contribution. There is nothing in the record indicating otherwise, and petitioner does not argue otherwise.”
    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.