Smith v. Commissioner’s Empirical Analysis
1985
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 44 later decisions — most recently August 2019 · most notably Gefen v. Commissioner (1986), Coleman v. Commissioner (1986)
2 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
Relies on Deputy v. du Pont · Commissioner v. Tufts · Southern Pacific Transp. Co. v. Commissioner · Hynes v. Commissioner · Barran 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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Interest paid by the taxpayer on a mortgage upon real estate of which he is the legal or equitable owner, even though the taxpayer is not directly liable upon the bond or note secured by such mortgage, may be deducted as interest on his indebtedness.”
2 later decisions quote this exact passage“liabilities to which the property is subject.”
2 later decisions quote this exact passage“So long as the transferred property remains liable on the debt, then, such debt can be a section 357(c) liability even if the petitioner retained personal, unrelieved liability on it.”
1 later decision quote this exact passagee.g. Owen v. Commissioner
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.