Foster v. Comm'r’s Empirical Analysis
1983
Citation profile
15 federal appellate ·
How this case has been cited
Cited by 128 later decisions — most recently October 2019 · most notably Howard S. Scar and Ethel M. Scar v. Commissioner of Internal Revenue (1987), Patin v. Commissioner (1987)
15 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 26 U.S.C. § 266
Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · Commissioner of Internal Revenue v. Duberstein D Stanton · Deputy v. du Pont · Helvering v. Taylor
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 128 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Section 482 may, when necessary to prevent the avoidance of taxes or to clearly reflect income, be applied....”
3 later decisions quote this exact passage · from the concurrence“the tax savings to an individual realized by preserving a partnership loss may very well exceed the tax cost to his corporation incurred by reporting the income.”
2 later decisions quote this exact passage · from the concurrence“only highly appreciated inventory pregnant with income was conveyed.”
2 later decisions quote this exact passage · from the concurrence
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.