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← 765 F.2d 643 - Saviano v. Commissioner

Saviano v. Commissioner’s Empirical Analysis

1985

Citation profile

138
cited by 138 later decisions
4
states following
August 2024
most recently cited

39 federal appellate · 5 district · 4 state decisions

How this case has been cited

Cited by 138 later decisions — most recently August 2024 · most notably Neonatology Associates Pa v. Commissioner of Internal Revenue (2002), Freytag v. Commissioner (1987)

39 federal appellate · 5 district · 4 state decisions

72019851990200020102020decided

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. § 108 · 26 U.S.C. § 465 · 26 U.S.C. § 616 · 26 U.S.C. § 7482 · 26 U.S.C. § 752

Relies on Lucas v. Earl · Crane v. Commissioner · Commissioner of Internal Revenue v. P G Lake · Burnet v. Logan · Griffiths v. Helvering

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 138 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The freedom to arrange one's affairs to minimize taxes does not include the right to engage in financial fantasies with the expectation that the Internal Revenue Service will play along.”
    24 later decisions quote this exact passage
  2. “[P]arties may not stipulate to the legal conclusions to be reached by the court.”
    3 later decisions quote this exact passage
  3. “parties to a lawsuit are free to stipulate to factual matters.”
    2 later decisions 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.