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← 92 TC 376 - Foil v. Commissioner

Foil v. Commissioner’s Empirical Analysis

1989

Citation profile

56
cited by 56 later decisions
January 2019
most recently cited

1 federal appellate ·

How this case has been cited

Cited by 56 later decisions — most recently January 2019 · most notably Cal-Maine Foods, Inc. v. Commissioner (1989), Roberts v. Commissioner (2013)

1 federal appellate ·

2101989199020002010decided

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. § 401 (Self-Employed Individuals Tax Retirement Act of 1962) · 26 U.S.C. § 414 (§ 1015 of the Employee Retirement Income Security Act of 1974) · 26 U.S.C. § 415 (§ 2004 of the Employee Retirement Income Security Act of 1974) · 26 U.S.C. § 457

Relies on Welch v. Helvering · Tennessee Valley Authority v. Hill · Commissioner of Internal Revenue v. Estate J Bosch Second National Bank of New Haven · Aaron v. Securities & Exchange Commission · Barr v. United States

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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “(3) Deferred compensation plans for State judges. --”
    3 later decisions quote this exact passage
  2. “is a reference to the amendments made by section 131 of R.A. 1978; the major such amendment is the one made by section 131(a) of R.A. 1978, adding section 457 to the Internal Revenue Code of 1954 . Thus, the direct effect of the new paragraph (3)(A) is to provide that section 457 of the Internal Revenue Code does not apply to”
    2 later decisions quote this exact passage
  3. “eligible State deferred compensation plan,”
    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.