Park v. Commissioner’s Empirical Analysis
722 F.3d 384 · 2013
Citation profile
2
cited by 2 later decisions
February 2016
most recently cited
Relationships
Applies 26 U.S.C. § 165 · 26 U.S.C. § 6662 · 26 U.S.C. § 871 · 26 U.S.C. § 873
Relies on United States v. Mead Corp. · Barnhill v. Johnson · Barba v. United States
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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The IRS has persuasively interpreted the term “gains” in Section 165(d) to allow U.S. citizens to measure gains on a per-session basis. The IRS stated that “gain or loss may be calculated over a series o f separate plays or wagers.” Memorandum AM2008-11, Office of Chief Counsel, Internal Revenue Service 4 (2008). Turning back to Section 871, we see again that Section 871 uses' the same key term that Section 165(d) uses — “gains.” And the logic and analysis of the IRS’s per-session approach to U.S. taxpayers in Section 165(d) has no less force when applied to non-resident aliens in Section 871.”
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.