Arrigoni v. Commissioner’s Empirical Analysis
1980
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 34 later decisions — most recently November 2004 · most notably Levit Vn v. Ingersoll Rand Financial Corporation (1989), Kean v. Commissioner (1988)
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
Relies on United States v. Sotelo · Bloom v. United States · Guardian Investment Corp. v. Phinney · Shiman v. Commissioner · Stout 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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a debt which arises from a debtor-creditor relationship based upon a valid and enforceable obligation to pay a fixed or determinable sum of money.”
3 later decisions quote this exact passage“Interest accruing during the time a taxpayer is secondarily liable for a debt is not deductible as such when paid, but is treated as a payment of principal. Only interest accruing when the taxpayer is primarily liable on a debt is treated as 'interest on indebtedness' for the purpose of section 163(a).”
2 later decisions quote this exact passage · from the majority“not permit the taxpayer to transform a nondeductible personal obligation into a deductible corporate debt when to do so would circumvent the effectiveness of sec. 6672 . But see First National Bank of Duncanville v. United States [ 481 F. Supp. 633 ↩ (N.D. Tex. 1979)] .”
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.