Bohrer v. Commissioner’s Empirical Analysis
1991
Citation profile
19 federal appellate · 3 district ·
How this case has been cited
Cited by 34 later decisions — most recently March 2010 · most notably Duffie v. United States (2010), United States v. Fleming (1994)
19 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. § 1092 · 26 U.S.C. § 1234 · 26 U.S.C. § 165
Relies on Gregory v. Helvering · Knetsch v. United States · Frank Lyon Co. v. United States · Rita v. United States · Breininger v. Sheet Metal Workers International Ass'n Local Union No. 6
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] transaction will be accorded tax recognition only if it has economic substance which is compelled or encouraged by business or regulatory realities, is imbued with tax-independent considerations, and is not shaped solely by tax avoidance features that have meaningless labels attached.”
3 later decisions quote this exact passage · from the majority“`incurred in any transaction entered into for profit' as required by I.R.C. § 165(c)(2).”
2 later decisions quote this exact passage · from the majority“any loss sustained during the taxable year and not compensated for by insurance or otherwise.”
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.