Zmuda v. Commissioner’s Empirical Analysis
1984
Citation profile
68 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 426 later decisions — most recently March 2021 · most notably Freytag v. Commissioner (1987), Allen v. Commissioner (1991)
68 federal appellate · 2 district · 2 state decisions
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
Applies 26 U.S.C. § 212 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 6653 · 26 U.S.C. § 671
Relies on Mullane v. Central Hanover Bank & Trust Co. · Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Commissioner v. Tower · Moline Properties, Inc. 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 426 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“extensive continuing press coverage of questionable tax shelter plans.”
23 later decisions quote this exact passage · from the majority“Although the taxpayer may structure a transaction so that it satisfies the formal requirements of the Internal Revenue Code, the Commissioner may deny legal effect to a transaction if its sole purpose is to evade taxation.”
5 later decisions quote this exact passage · from the majority“attempts to create a distinction where none exists. There is no real difference between the business purpose and the economic substance rules. Both simply state that the Commissioner may look beyond the form of an action to discover its substance.”
2 later decisions 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.