Leahy v. Commissioner

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• failing to argue against liability for addition to tax under section 6651(a) at trial or on brief is a deemed concession
• transfer of the benefits and burdens of ownership govern for Federal tax purposes, rather than the technical requirements of passage of title under State law
• transfer of the benefits and burdens of ownership govern for Federal tax purposes, rather than the technical requirements of passage of title under State law
• addition to tax deemed conceded when not mentioned in brief and no evidence presented at trial
• transfer of the benefits and burdens of ownership govern for Federal tax purposes, rather than the technical requirements of passage of title under State law
• Commissioner originally contended that partnership was not entitled to investment tax credit on ground that partnership was not owner of the property; later ground was alleged failure to attach statement to return, as required by regulations

Source: CourtListener parenthetical corpus (CC0).

Cited by

11 cases in this archive cite this case.

• Zirker v. Commissioner
  U.S. Tax Court· 1986-10-30· cited 151×
• Stephen A. Mahoney, Iii, and Mary Ann Mahoney v. Commissioner of Internal Revenue
  Sixth Circuit· 1987-01-14· cited 89×
• Pagel, Inc. v. Commissioner
  U.S. Tax Court· 1988-08-08· cited 69×
• Rogers v. United States
  Tenth Circuit· 2002-02-22· cited 37×
• Bussing v. Commissioner
  U.S. Tax Court· 1987-02-23· cited 37×
• Berkery v. Commissioner
  U.S. Tax Court· 1988-02-16· cited 31×
• Kramer v. Commissioner
  U.S. Tax Court· 1987-11-25· cited 18×
• Krumhorn v. Comm'r
  U.S. Tax Court· 1994-07-19· cited 17×
• In Re Gran
  E.D. Arkansas· 1989-11-27· cited 9×
• RCA Corp. v. United States
  Court of Claims· 1987-06-30· cited 3×
• Mylan, Inc. & Subsidiaries
  U.S. Tax Court· 2021-04-27

Cites

22 cases in this archive are cited by this case; the 20 most cited are listed.

• Welch v. Helvering
  Supreme Court· 1933-11-06· cited 9,823×
• Gregory v. Helvering
  Supreme Court· 1935-01-07· cited 2,523×
• Frank Lyon Co. v. United States
  Supreme Court· 1978-04-18· cited 810×
• Commissioner v. Brown
  Supreme Court· 1965-04-27· cited 494×
• Estate of Charles T. Franklin, Deceased v. Commissioner of Internal Revenue
  Ninth Circuit· 1976-11-01· cited 309×
• Grodt & McKay Realty, Inc. v. Commissioner
  U.S. Tax Court· 1981-12-07· cited 298×
• Estate of Franklin v. Commissioner
  U.S. Tax Court· 1975-07-30· cited 242×
• Estate of Horvath v. Commissioner
  U.S. Tax Court· 1973-01-18· cited 204×
• Estate of Thomas v. Commissioner
  U.S. Tax Court· 1985-03-14· cited 126×
• Spencer D. Stewart, Et Ux. v. Commissioner of Internal Revenue
  Ninth Circuit· 1983-09-02· cited 86×
• Houchins v. Commissioner
  U.S. Tax Court· 1982-09-29· cited 73×
• Derr v. Commissioner
  U.S. Tax Court· 1981-09-29· cited 67×
• Podell v. Commissioner
  U.S. Tax Court· 1970-12-09· cited 53×
• Goldsmith v. Commissioner of Internal Revenue
  Second Circuit· 1944-06-14· cited 43×
• Michael Todd Co. v. County of Los Angeles
  California Supreme Court· 1962-05-17· cited 40×
• Daniel M. Cory and Margot Cory, His Wife, Petitioners-On-Review v. Commissioner of Internal Revenue, Respondent-On-Review
  Second Circuit· 1956-03-09· cited 29×
• Commissioner of Internal Revenue v. Erie Forge Co.
  Third Circuit· 1948-03-09· cited 27×
• Misbourne Pictures Limited v. Johnson
  Second Circuit· 1951-06-11· cited 23×
• Goldsmith v. Commissioner
  U.S. Tax Court· 1943-03-05· cited 21×
• Carnegie Productions, Inc. v. Commissioner
  U.S. Tax Court· 1973-02-05· cited 19×