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← 82 TC 705 - Smith v. Commissioner

Smith v. Commissioner’s Empirical Analysis

1984

Citation profile

25
cited by 25 later decisions
May 2002
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 25 later decisions — most recently May 2002 · most notably Elrod v. Commissioner (1986), Estate of Durkin v. Commissioner (1992)

2 federal appellate ·

160198419902000decided

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 Welch v. Helvering · Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Golsen v. Commissioner · Golsen 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[W]e are not bound by the parties' labels, but only by the facts.”
    2 later decisions quote this exact passage
  2. “Although the individual terms of the original agreement and addendum, when examined separately, appear clear, we find the language irreconcilable and hence ambiguous when the original agreement and addendum are applied and interpreted together.”
    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.