Levy v. Commissioner’s Empirical Analysis
1988
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 100 later decisions — most recently June 2018 · most notably Laureys v. Commissioner (1989), Young v. Commissioner (1991)
9 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 Frank Lyon Co. v. United States · Dreicer v. Commissioner · Fruit Growers Exp. Co. v. Brotherhood Ry. Carmen of U. S. And Canada, Ry. Employees' Dept., Afl-Cio · Rice's Toyota World, Inc. v. Commissioner · Estate of Charles T. Franklin, Deceased 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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(4) Exception. — Notwithstanding any other provision of this section, a taxpayer shall not be considered at risk with respect to amounts protected against loss through nonrecourse financing, guarantees, stop loss agreements, or other similar arrangements.”
4 later decisions quote this exact passage · from the majority“must be resolved on the basis of who realistically will be the payor of last resort if the transaction goes sour and the secured property associated with the transaction is not adequate to pay off the debt.”
4 later decisions quote this exact passage · from the majority“the scenario that controls is the worst case scenario, not the best case.”
4 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.