Tolwinsky v. Commissioner’s Empirical Analysis
1986
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 63 later decisions — most recently November 2006 · most notably Rose v. Commissioner (1987), Kirchman v. Commissioner (1989)
12 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 17 U.S.C. § 101 (§ 101 of the Copyright Act of 1976) · 17 U.S.C. § 106 (§ 101 of the Copyright Act of 1976) · 17 U.S.C. § 201 (§ 101 of the Copyright Act of 1976) · 17 U.S.C. § 202 (§ 101 of the Copyright Act of 1976) · 26 U.S.C. § 465
Relies on Welch v. Helvering · Cohan v. Commissioner · Helvering v. Clifford · Commissioner of Internal Revenue v. Court Holding Co · Corliss v. Bowers
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 63 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(determined without regard to useful life) which is a”
4 later decisions quote this exact passage · from the concurrence“[t]o qualify for the investment credit with respect to a qualified film, the taxpayer must have a depreciable interest in at least a part of the film. Solely for purposes of this paragraph, a taxpayer who, at the time a film is first placed in service, is a lender or guarantor of all or a portion of the funds used to produce or acquire the film or part thereof, will be regarded as having a depreciable interest in at least a part of the film if he can look for repayment or relief from liability solely to the proceeds generated from the exhibition or disposition of at least a part of the film.”
3 later decisions quote this exact passage · from the concurrence“means the exclusive right to display a qualified film in one or more mediums of exhibition in one or more geographical areas over the entire period of substantial exploitation of the film in the medium(s) in the geographical area(s).”
3 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.