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← 92 TC 1 - Allen v. Commissioner

Allen v. Commissioner’s Empirical Analysis

1989

Citation profile

179
cited by 179 later decisions
January 2020
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 179 later decisions — most recently January 2020 · most notably Allen v. Commissioner (1991), BUNNEY v. COMMISSIONER OF INTERNAL REVENUE (2000)

2 federal appellate ·

66019891990200020102020decided

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 · Deputy v. du Pont · Neely 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 179 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “the three Bizar-related entities, [the Institute], IBN, and [the Funding Corporation], worked as a functionally integrated whole.”
    1 later decision quote this exact passage
  2. “except with respect to the cash portion of a contribution, the [Bizar] unit was not enriched by a donor's 'contribution.'”
    1 later decision quote this exact passage
  3. “lack of due care or failure to do what a reasonable and ordinarily prudent person would do under the circumstances.”
    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.