Horn v. Commissioner’s Empirical Analysis
1992
Citation profile
8 federal appellate · 3 district · 4 state decisions
How this case has been cited
Cited by 46 later decisions — most recently March 2021 · most notably Neonatology Associates Pa v. Commissioner of Internal Revenue (2002), Rogers v. United States (2002)
8 federal appellate · 3 district · 4 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
Applies 26 U.S.C. § 1092 · 26 U.S.C. § 1234 · 26 U.S.C. § 1256 · 26 U.S.C. § 1402 · 26 U.S.C. § 165 · 26 U.S.C. § 7482
Relies on Missouri v. Continential Insurance Cos. · Gregory v. Helvering · Robertson v. Methow Valley Citizens Council · Knetsch v. United States · Frank Lyon Co. v. United States
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]here . . . there is a genuine multiple-party transaction with 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, the Government should honor the allocation of rights and duties effectuated by the parties.”
2 later decisions quote this exact passage · from the majority“To treat a transaction as a sham, the court must find [1] that the taxpayer was motivated by no business purpose other than obtaining tax benefits in entering the transaction, and [2] that the transaction has no economic substance because no reasonable possibility of profit exists.”
2 later decisions quote this exact passage · from the majority“which actually occurred but which exploit[s] a feature of the tax code without any attendant economic risk,”
2 later decisions quote this exact passage · from the concurrencee.g. Neonatology Associates, P.A. v. Commissioner of Internal Revenue (Tax Court No. 97-1201) John J. And Ophelia J. Mall v. Commissioner of Internal Revenue (Tax Court No. 97-1208) Estate of Steven Sobo, Deceased and Bonnie Sobo, and Bonnie Sobo, Surviving Wife v. Commissioner of Internal Revenue (Tax Court No. 97-2795) Akhileshi S. And Dipti A. Desai v. Commissioner of Internal Revenue (Tax Court No. 97-2981) Kevin T. And Cheryl McManus v. Commissioner of Internal Revenue (Tax Court No. 97-2985) Arthur and Lois M. Hirshkowitz v. Commissioner of Internal Revenue (Tax Court No. 97-2994) Lakewood Radiology, P.A. v. Commissioner of Internal Revenue (Tax Court No. 97-2995) Neonatology Associates, P.A., John J. And Ophelia Mall, Estate of Steven Sobo, Deceased, and Bonnie Sobo, and Bonnie Sobo, Surviving Wife, Akhilshi S. And Dipti A. Desai, Kevin T. And Cheryl McManus Arthur and Lois M. Hirshkowitz and Lakewood Radiology, P.A. · Neonatology Associates Pa v. Commissioner of Internal Revenue
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.