Garner v. Commissioner’s Empirical Analysis
1993
Citation profile
3 federal appellate · 1 state decisions
How this case has been cited
Cited by 10 later decisions — most recently January 2018
3 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
Applies 26 U.S.C. § 166
Relies on Whipple v. Commissioner · Putnam v. Commissioner · United States v. Generes · Hirsch v. Commissioner · Putoma 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'proximate relationship' between the debt and the taxpayer's business.”
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.