Cozzi v. Commissioner’s Empirical Analysis
1987
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 74 later decisions — most recently March 2019 · most notably Friedman v. Commissioner (2000), Merkel v. Commissioner (1997)
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
Applies 26 U.S.C. § 6653
Relies on Welch v. Helvering · Helvering v. Taylor · United States v. Janis · Commissioner of Internal Revenue v. Court Holding Co · United States v. S S White Dental Mfg Co of Pennsylvania
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The moment it becomes clear that a debt will never have to be paid, such debt must be viewed as having been discharged.”
10 later decisions quote this exact passage“Any 'identifiable event' which fixes the loss with certainty may be taken into consideration.”
4 later decisions quote this exact passage“The general theory is that to the extent that a taxpayer has been released from indebtedness, he has realized an accession to income because the cancellation effects a freeing of assets previously offset by the liability arising from such indebtedness.”
2 later decisions 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.