Echols v. Commissioner’s Empirical Analysis
1989
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 12 later decisions — most recently December 2019
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 Andrew v. Commissioner · Freeland v. Commissioner · Hopkins v. Commissioner · Middleton v. Commissioner · Middleton 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We think that [the Partnership's] failure to manifest its abandonment through some act apparent to those outside of the partnership is a point which distinguishes this case from Middleton.... While we do not hold that conveyance or even tender of title is necessary to consummate an abandonment, we do hold that for an abandonment to be effective for purposes of section 165(a), the abandoning party must manifest an intent to abandon by some overt act or statement reasonably calculated to give a third party notice of the abandonment. Petitioner[s] bear[ ] the burden of proof in this case, and [they have] produced no evidence of any such act or statement that was not confined to [the Partnership's] partners. We therefore find that the earliest identifiable event to which a recognizable loss may be tied is the actual foreclosure, which occurred after the year in which the loss was claimed.”
1 later decision 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.