Richardson v. Commissioner’s Empirical Analysis
1981
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 21 later decisions — most recently March 2014
4 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 42 U.S.C. § 1988
Relies on Commissioner of Internal Revenue v. Glenshaw Glass Company · Estate of Horvath v. Commissioner · Key Buick Co. v. Commissioner · Ennis v. Commissioner · Key Buick Co. 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“at the end of the partnership year in which such loss occurred.”
2 later decisions quote this exact passage“to make it clear that the varying interests rule of this provision is to apply to any partner whose interest in a partnership is reduced, whether by entry of a new partner who purchased his interest directly from the partnership, partial liquidation of a partner’s interest, gift, or otherwise. Correspondingly, the provision is to apply to the incoming partner so as to take into account his varying interests during the year. In addition, regulations are to apply the same alternative methods of computing allocations of income and loss to situations falling under section 706(c)(2)(B) as those now applicable to section 706(c)(2)(A) situations (sale or liquidation of an entire interest).”
1 later decision quote this exact passage“(c) Closing of Partnership Year.— [[Image here]] (2) Partner who retires or sells interest in partnership.— [[Image here]] (B) Disposition of less than entire interest:— The taxable year of a partnership shall not close (other than at the end of a partnership’s taxable year as determined under subsection (b)(1)) with respect to a partner who sells or exchanges less than his entire interest in the partnership or with respect to a partner whose interest is reduced, but such partner’s distributive share of items described in section 702(a) shall be determined by taking into account his varying interests in the partnership during the taxable year.”
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.