Rosenberg v. Commissioner’s Empirical Analysis
1991
Citation profile
1 federal appellate · 1 state decisions
How this case has been cited
Cited by 6 later decisions — most recently January 2012
1 federal appellate · 1 state decisions
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 Hillsboro National Bank v. Commissioner · Hudspeth v. Commissioner of Internal Revenue Service · Home Mutual Insurance v. Commissioner · Schwartz Rojas v. Commissioner · Capitol Coal Corp. 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[n]o carryforward, and no carryback, arising for a taxable year for which a corporation is a C corporation may be carried to a taxable year for which such corporation is an S corporation.”
2 later decisions quote this exact passage“The corollary, emphasizing the inclusionary aspect, is that when an item previously deducted by the taxpayer is restored, it must be included in income to the extent that the earlier loss (deduction) generated a tax benefit.”
1 later decision quote this exact passage“Section 1371(b)(1) . . . is only one of several provisions designed to prevent abuses of the S corporation election.”
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.