Rogers v. Commissioner’s Empirical Analysis
103 F.2d 790 · 1939
Citation profile
21 federal appellate · 1 district ·
How this case has been cited
Cited by 44 later decisions — most recently January 1992 · most notably Hirsch v. Commissioner (1941), Gruver v. Commissioner (1944)
21 federal appellate · 1 district ·
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. § 101
Relies on Eisner v. Macomber · United States v. Hendler · State of Lowa v. McFarland State of Illinois · Hale v. Helvering · Watson 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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A sale, in the ordinary sense of the word, is a transfer of property for a fixed price in money or its equivalent.”
4 later decisions quote this exact passage · from the majority““There was no showing or intimation that the petitioners were financially unable to pay the indebtedness. The situation is analogous to one where the mortgagor sells the property to a third party for a sum equal to the amount due on his note and then pays the note with that money. The result to the taxpayer would be exactly the same as here, although it could not there be maintained that the taxpayer received nothing of value for the property.””
2 later decisions quote this exact passage · from the majority“* * * `capital assets' means property held by the taxpayer (whether or not connected with his trade or business), but does not include stock in trade of the taxpayer * * *.”
2 later decisions 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.