Honodel v. Commissioner’s Empirical Analysis
1981
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 22 later decisions — most recently October 2002
2 federal appellate ·
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 12 U.S.C. § 1715Z
Relies on Cohan v. Commissioner · United States v. Gilmore · Bingham's Trust v. Commissioner of Internal Revenue · Helvering v. Winmill · Woodward 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Only those clients who decided to invest in a recommended project and took advantage of FMS’s acquisition function paid the investment fees. Those clients who chose not to invest and hence were not required to pay the investment fee received the exact same investment services as those who chose to invest. Conversely, petitioners could only participate in an investment if they paid the investment fee. Each petitioner voluntarily could choose to invest in the projects. Each was cognizant of the fact that a decision to invest resulted in the imposition of this investment fee. This investment fee was a cost of acquiring an interest in the limited partnership projects herein.”
2 later decisions quote this exact passage“'the nature of the services performed' by the investment adviser rather than 'their designation or treatment' by the taxpayer.”
2 later decisions quote this exact passage“The law could hardly be otherwise, for such ancillary expenses incurred in acquiring or disposing of an asset are as much part of the cost of that asset as is the price paid for it.”
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.