William L. Becker v. Commissioner of Internal Revenue’s Empirical Analysis
1985
Citation profile
6 federal appellate · 2 district ·
How this case has been cited
Cited by 23 later decisions — most recently December 2012
6 federal appellate · 2 district ·
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. § 265
Relies on Haines v. Kerner · Helvering v. Taylor · Automobile Club of Mich. v. Commissioner · Dixon v. Unied States · Dickman 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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“at the time that Manocchio was decided by the Tax Court, the Commissioner had not issued Revenue Ruling 83-3 which disallowed the deduction of educational expenses that were allocable to a portion of the veterans’ educational benefits other than flight training. This ruling, however, was prospective only. After the Tax Court had rendered its decision in this case, the Courts of Appeals for the Ninth and Eleventh Circuits reached different conclusions as to whether the application of Revenue Rulings 80-173 and 83-3 have resulted in the disparate treatment of similarly situated taxpayers. Manocchio v. Commissioner, 710 F.2d 1400 , 1404 & n. 2 (9th Cir. 1983) (holding that there is a rational basis for the distinction); Baker v. United States, 748 F.2d 1465 (11th Cir. 1984) (holding that there is no rational reason for the retroactive application of 80-173 and the prospective application of 83-3). Thus, there may be some question as to the soundness of the Tax Court’s reliance on Manocchio due to the Commissioner’s subsequent revenue ruling. [ 751 F.2d at 151-152 .]”
1 later decision quote this exact passage · from the majority“solely to afford the taxpayer an opportunity to present to the Tax Court his contention that the Tax Court erred in not finding that the Commissioner abused his discretion in applying Revenue Ruling 80-173 retroactively as to him in violation of the taxpayer’s right to equal treatment in the application of the tax laws. [Becker v. Commissioner, 751 F.2d 146, 152 (1984).]”
1 later decision quote this exact passage · from the majority“expenses for education, paid or incurred by veterans, which are properly deductible for Federal income tax purposes, are not required to be reduced by the nontaxable payments received during the taxable year from the Veterans’ Administration. [1962-2 C.B. at 59.]”
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.