Smith v. Commissioner’s Empirical Analysis
1991
Citation profile
23 federal appellate · 1 district ·
How this case has been cited
Cited by 51 later decisions — most recently September 2011 · most notably Thomas v. United States (1999), Harris v. Commissioner (1994)
23 federal appellate · 1 district ·
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. § 7482
Relies on Anderson v. City of Bessemer City · United States v. United States Gypsum Co. · Snow v. Commissioner · Rice's Toyota World, Inc. v. Commissioner · Rose 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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]ctual control [of the partnerships] rested in persons whose compensation from these partnerships depended solely on capital contributions, while they had interests in the profitability of competing ventures.”
2 later decisions quote this exact passage · from the dissent“We find it error to have concluded on the facts and record that the Smiths were motivated by “no business purposes” * * *. [Smith v. Commissioner, 937 F.2d at 1098-1099 ; emphasis in original.]”
1 later decision quote this exact passage · from the dissent“the legal standard applied by the Tax Court and its legal conclusions based upon its findings of fact are reviewed de novo.”
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.