Rogers v. Commissioner’s Empirical Analysis
728 F.3d 673 · 2013
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 1366 · 26 U.S.C. § 6221 · 26 U.S.C. § 6662
Relies on Beatty v. . Guggenheim Exploration Co. · Superior Trading, LLC v. Commissioner · Wal-Mart Stores, Inc. Associates' Health & Welfare Plan v. Wells · Rodrigues v. Herman
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But the Tax Court ruled in the present case that the money received by PPI and either retained by it or distributed to Rogers but not forwarded to Warwick was not held in trust for Warwick—it was PPI's money—and so the tax status of that money was not an issue for resolution in a partnership-level case .”
1 later decision quote this exact passage · from the majority“When property has been acquired in such circumstances that the holder of the legal title may not in good conscience retain the beneficial interest equity converts him into a trustee.”
1 later decision quote this exact passage · from the majority“* * * and so not in this case, which is about personal not partnership income. * * * The Court of Appeals for the Seventh Circuit disposed of the argument succinctly:”
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.