Miller v. Commissioner’s Empirical Analysis
1980
Citation profile
4
cited by 4 later decisions
October 1999
most recently cited
Relationships
Applies 26 U.S.C. § 24
Relies on United States v. Davis · McWilliams v. Commissioner · Bradbury v. Commissioner · Blum v. Commissioner · Haft Trust 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Section 24(b) states an absolute prohibition — not a presumption — against the allowance of losses on any sales between the members of certain designated groups. The one common characteristic of these groups is that their members, although distinct legal entities, generally have a near-identity of economic interests. It is a fair inference that even legally genuine intra-group transfers were not thought to result, usually, in economically genuine realizations of loss, and accordingly that Congress did not deem them to be appropriate occasions for the allowance of deductions. [ 331 U.S. at 699 . Fn. ref. omitted.]”
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.