Rice's Toyota World, Inc. v. Commissioner’s Empirical Analysis
752 F.2d 89 · 1985
Citation profile
103 federal appellate · 4 district · 7 state decisions
How this case has been cited
Cited by 343 later decisions — most recently February 2026 · most notably United States v. Adlman (1998), Rose v. Commissioner (1987)
103 federal appellate · 4 district · 7 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
Relies on Gregory v. Helvering · Knetsch v. United States · Frank Lyon Co. v. United States · Crane v. Commissioner · Commissioner v. Tufts
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 343 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“To treat a transaction as a sham, the court must find that the taxpayer was motivated by no business purposes other than obtaining tax benefits in entering the transaction, and that the transaction has no economic substance because no reasonable possibility of a profit exists.”
24 later decisions quote this exact passage · from the majority“requires an objective determination of whether a reasonable possibility of profit from the transaction existed apart from the tax benefits.”
9 later decisions quote this exact passage · from the majoritye.g. Baxter v. Comm'r · Austin v. Comm'r“is a sham is an issue of fact, and our review of the tax court's subsidiary and ultimate findings on this factual issue is therefore under the clearly erroneous standard”
8 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.