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← 76 TC 239 - Major v. Commissioner

Major v. Commissioner’s Empirical Analysis

1981

Citation profile

64
cited by 64 later decisions
February 2016
most recently cited

6 federal appellate ·

How this case has been cited

Cited by 64 later decisions — most recently February 2016 · most notably Fono v. Commissioner (1982), Miami Purchasing Service Corp. v. Commissioner (1981)

6 federal appellate ·

3901981199020002010decided

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 · Commissioner of Internal Revenue v. Court Holding Co · Higgins v. Smith · Golsen v. Commissioner · Golsen 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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[i]n light of the preference in this Court to apply the strong proof standard as applied to the intention of the parties, we shall proceed on the basis that this is acceptable to the Seventh Circuit.”
    2 later decisions quote this exact passage
  2. “standard favored by the Tax Court and enunciated in Major v. Commissioner: 20 [W]here one alleges that an allocation is actually other than that contained in a contract, that party must prove it beyond a mere preponderance of the evidence--he must present”
    1 later decision quote this exact passage
  3. “We do not suggest that the covenant had no value, but merely that evidence shows that at the time of contracting, the covenant possessed no more than an unascertainable de minimis value.”
    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.