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← 79 TC 714 - Zmuda v. Commissioner

Zmuda v. Commissioner’s Empirical Analysis

1982

Citation profile

326
cited by 326 later decisions
1
states following
July 2019
most recently cited

4 federal appellate · 1 state decisions

How this case has been cited

Cited by 326 later decisions — most recently July 2019 · most notably Freytag v. Commissioner (1987), Zmuda v. Commissioner (1984)

4 federal appellate · 1 state decisions

19201982199020002010decided

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. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 671

Relies on Gregory v. Helvering · Cohan v. Commissioner · Bixby v. Commissioner · Hatfield v. Commissioner · Markosian 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 326 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “When the form of the transaction has not, in fact, altered any cognizable economic relationships, we will look through that form and apply the tax law according to the substance of the transaction.”
    4 later decisions quote this exact passage
  2. “not compensated for by insurance or otherwise.”
    4 later decisions quote this exact passage · from the majority
  3. “The interest [received by Buena],is in-cludible in [petitioners’] gross income in accordance with section 61(a)(4) of the Internal Revenue Code. An alternative position is that if the interest has been included in the income of a trust organization and if the trust organization was found to be a valid trust, then the trust would be a grantor trust and the interest is includible in your gross income in accordance with section 671 of the Internal Revenue Code.”
    2 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.