Hunt v. Commissioner’s Empirical Analysis
1991
Citation profile
12 federal appellate · 3 district ·
How this case has been cited
Cited by 31 later decisions — most recently December 2018 · most notably Pasternak v. Commissioner (1993), Anderson v. Commissioner (1995)
12 federal appellate · 3 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. § 6621
Relies on Frank Lyon Co. v. United States · Rice's Toyota World, Inc. v. Commissioner · Antonides v. Commissioner · Rose 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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“motivated by no business purposes other than obtaining tax benefits.”
2 later decisions quote this exact passage · from the majority“substantial underpayment attributable to tax motivated transactions”
2 later decisions quote this exact passage · from the majority“[w]hile it is important to examine both the subjective motivations of the taxpayer and the objective reasonableness of the investment, in both instances our inquiry is directed to the same question: whether the transaction contained economic substance aside from the tax consequences.”
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.