Brown v. Commissioner’s Empirical Analysis
1985
Citation profile
10 federal appellate · 1 state decisions
How this case has been cited
Cited by 99 later decisions — most recently July 2018 · most notably Freytag v. Commissioner (1987), Sochin v. Commissioner (1988)
10 federal appellate · 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
Relies on Welch v. Helvering · New Colonial Ice Co. v. Helvering · Gregory v. Helvering · Higgins v. Smith · Knetsch v. United States
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 99 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“failed to establish that the entire [investment] program ... did not exist solely to provide tax benefits for its investors,”
2 later decisions quote this exact passage“the losses claimed by [Taxpayers] are not allowable because the disputed transactions constituted factual shams which were inspired, designed, and executed by Mr. Gregory and the two corporations controlled by him for the sole purpose of attempting to achieve tax losses for their investors.”
1 later decision quote this exact passage“Inasmuch as we have found that the program was operated solely to provide tax deductions for its participants, the fees constituted payments to purchase such deductions and as such are, at best, personal expenditures which are not deductible.”
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.