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← 77 TC 113 - O'Brien v. Commissioner

O'Brien v. Commissioner’s Empirical Analysis

1981

Citation profile

16
cited by 16 later decisions
1
states following
April 2008
most recently cited

2 federal appellate · 1 state decisions

How this case has been cited

Cited by 16 later decisions — most recently April 2008

2 federal appellate · 1 state decisions

80198119902000decided

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 Zeeman v. United States · Hutcheson v. Commissioner · Freeland v. Commissioner · 275 F. Supp. 235 - Zeeman v. United States · Stilwell 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “abandonment of his partnership interest resulted in a decrease in his share of the partnership liabilities within the meaning of section 752(b) , not because he ever had personal liability under State law, but because he is no longer considered under the applicable Code provisions as sharing in the nonrecourse liabilities of the partnership.”
    3 later decisions quote this exact passage
  2. “where none of the partners have any personal liability with respect to a partnership liability (as in the case of a mortgage on real estate acquired by the partnership without the assumption by the partnership or any of the partners of any liability on the mortgage), then all partners, including limited partners, shall be considered as sharing such liability under section 752(c) in the same proportion as they share the profits. * * *”
    1 later decision quote this exact passage
  3. “Recognition of Gain or Loss on Distribution .”
    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.