Rodriguez v. Commissioner’s Empirical Analysis
722 F.3d 306 · 2013
Citation profile
5 federal appellate · 1 state decisions
Relationships
Applies 26 U.S.C. § 1 (Airport and Airway Extension Act of 2008) · 26 U.S.C. § 316 · 26 U.S.C. § 7482 · 26 U.S.C. § 851 · 26 U.S.C. § 904 · 26 U.S.C. § 951 · 26 U.S.C. § 956 · 26 U.S.C. § 959
Relies on Welch v. Henry · Milliken v. United States · United States v. Carlton · Microsoft Corp. v. i4i Ltd. Partnership · United States v. Darusmont
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Appellants could have caused a dividend to issue. They could have also paid themselves a salary or invested ... earnings elsewhere. Each of these decisions would have carried different tax implications, thereby altering our analysis. Appellants cannot now avoid their tax obligation simply because they regret the specific decision they made.”
1 later decision quote this exact passage · from the majority“[I]t is clear that Congress did not intend to deem as dividends the [ ] inclusions at issue here. The statute is completely silent [on the point,] a fact which carries added weight when compared to the myriad provisions specifically stating that certain income is to be treated as if it were a dividend.”
1 later decision quote this exact passage · from the majority“Congress specifically designates when § 951 inclusions are to be treated as dividends,”
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.