Selfe v. United States’s Empirical Analysis
778 F.2d 769 · 1985
Citation profile
26 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 90 later decisions — most recently August 2022 · most notably Estate Leavitt III III v. Commissioner of Internal Revenue, Estate of Leavitt v. Commissioner (1988)
26 federal appellate · 1 district · 1 state decisions
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. § 1374 · 26 U.S.C. § 385
Relies on Bonner v. City of Prichard · Higgins v. Smith · Commissioner of Internal Revenue v. National Alfalfa Dehydrating and Milling Company · Hall v. Cole · Don Williams Company v. Commissioner of Internal Revenue
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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the lender looks to the shareholder as the primary obligor.”
14 later decisions quote this exact passage · from the majority“a guarantor who has pledged stock to secure a loan has experienced an economic outlay to the extent that that pledged stock is not available as collateral for other investments”
7 later decisions quote this exact passage · from the majority“where the facts demonstrate that, in substance, the shareholder has borrowed funds and subsequently advanced them to her corporation.”
6 later decisions quote this exact passage · from the majority
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.