Ewing v. Commissioner’s Empirical Analysis
1988
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 126 later decisions — most recently August 2015 · most notably Neonatology Assocs., P.A. v. Comm'r (2000), Smith v. Commissioner (1988)
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 Welch v. Helvering · Neely v. Commissioner · Golsen v. Commissioner · Golsen v. Commissioner · Zmuda 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 126 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Q-3. If a loss is disallowed in a taxable year (year 1) because the transaction was not entered into for profit, is the entire gain from the straddle occurring in a later taxable year taxed? A-3. No. Under section 108(c) of the Act the taxpayer is allowed to offset the gain in the subsequent taxable year by the amount of loss (including expenses) disallowed in year 1.”
4 later decisions quote this exact passage · from the majority“attributable to 1 or more tax motivated transactions.”
4 later decisions quote this exact passage · from the majority“we are cognizant of the fact that tax planning is an economic reality in the business world and the effect of tax laws on a transaction is routinely considered”
2 later decisions quote this exact passage · from the majority
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.