green
Positive treatment
Quoted verbatim 2×
5.4 score
G Cite
cited 2× by 2 distinct cases, last quoted 1988 ·
…the supreme court has said that the determinative question is whether the taxpayer's purpose in entering into the transaction was primarily for profit.
⚠ not in text
Treatment trajectory · 1966 → 2026 · click a year to view as-of
1966
1996
2026
Top citers, strongest first. 6 distinct citers.
How cited ↗
discussed
Cited as authority (quoted)
Gilbert R. Miller and Rita Miller v. Commissioner of Internal Revenue, James B. Kurtz and Katherine Kurtz v. Commissioner of Internal Revenue, W.C. Kurtz, Jr. And Alma Mae Kurtz v. Commissioner of Internal Revenue, Dorchester Partners, Edward O. Thorp and Vivian S. Thorp I.C. Hemmings Chicago Board of Trade and Chicago Mercantile Exchange, Amici Curiae
the supreme court has said that the determinative question is whether the taxpayer's purpose in entering into the transaction was primarily for profit.
discussed
Cited as authority (quoted)
Miller v. Commissioner of Internal Revenue
the supreme court has said that the determinative question is whether the taxpayer's purpose in entering into the transaction was primarily for profit.
discussed
Cited "see"
Vons Companies, Inc. v. United States
See Knetsch v. United States, 172 Ct.Cl. 378 , 348 F.2d 932, 940 , 940 n. 14 (1965), cert. denied, 383 U.S. 957 , 86 S.Ct. 1221 , 16 L.Ed.2d 300 (1966); Bornstein v. United States, 170 Ct.Cl. 576 , 345 F.2d 558 , 564 n. 2 (1965). 9 Thus, IBM only ever so slightly expands the realm in which private letter rulings may be cited or used. 10 For its part, the Supreme Court has considered the precedential impact (or lack thereof) of private letter rulings or technical advice memoranda on three occasions.
discussed
Cited "see"
Bertha Lemle v. United States
See Knetsch v. United States, 348 F.2d 932, 940 , 172 Ct.Cl. 378 (1965), cert. denied, 383 U.S. 957 , 86 S.Ct. 1221 , 16 L.Ed.2d 300 (1966); Bornstein v. United States, 345 F.2d 558 , 563, 175 Ct.Cl. 576 (1965); Knapp-Monarch Co. v. Commissioner, 139 F.2d 863, 864 (8th Cir. 1944).
cited
Cited "see, e.g."
Sterling-Kates v. United States
See, e.g., Rough Diamond Co. v. United States, 173 Ct.Cl. 15 , 351 F.2d 636 (1965), cert. denied 383 U.S. 957 , 86 S.Ct. 1221 , 16 L.Ed.2d 300 (1966).
cited
Cited "see, e.g."
Arrowhead Metals, Ltd. v. United States
See also Rough Diamond Co. v. United States, 173 Ct.Cl. 15, 26 , 351 F.2d 636, 642 , (1965), cert. denied, 387 U.S. 957 , 86 S.Ct. 1221 , 16 L.Ed.2d 300 (1966).
Retrieving the full opinion text from the archive…
Rough Diamond Co., Inc.
v.
United States
v.
United States
No. 901.
Supreme Court of the United States.
Mar 28, 1966.
Carl L. Shipley for petitioners. Solicitor General Marshall, Assistant Attorney General Douglas, Alan S. Rosenthal and Edward Berlin for the United States.
Published
Citer courts: Tenth Circuit (2)
Ct. Cl. Certiorari denied.