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← 74 TC 60 - Gilbert v. Commissioner

Gilbert v. Commissioner’s Empirical Analysis

1980

Citation profile

34
cited by 34 later decisions
May 2018
most recently cited

3 federal appellate · 1 district ·

How this case has been cited

Cited by 34 later decisions — most recently May 2018 · most notably Yelencsics v. Commissioner (1980), Kean v. Commissioner (1988)

3 federal appellate · 1 district ·

1801980199020002010decided

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 Welch v. Helvering · Jasionowski v. Commissioner · Alterman Foods, Inc. v. United States · Litton Business Systems, Inc. v. Commissioner · Rushing 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.

  1. “[T]ransfers between related corporations can result in constructive dividends to their common shareholder if they were made primarily for his benefit and if he received a direct or tangible benefit”
    2 later decisions quote this exact passage
  2. “upon weighing such objective factors as reasonable expectation of repayment and the economic reality of the claimed debtor-creditor relationship.”
    1 later decision quote this exact passage
  3. “the transfer was consistently treated as a loan on the books ... and balance sheets of both corporations,”
    1 later decision quote this exact passage

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.