Michaels v. Commissioner’s Empirical Analysis
1949
Citation profile
8 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 82 later decisions — most recently April 2011 · most notably Hamlin's Trust v. Commissioner of Internal Revenue (1954), Ullman v. Commissioner (1957)
8 federal appellate · 1 district · 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
Relies on Toledo Blade Co. v. Commissioner (A) · Toledo Newspaper Co. v. Commissioner · Petit Anse Co. v. Commissioner · Rainier Brewing Co. v. Commissioner · X-Pando 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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If such an agreement [a covenant not to compete] can be segregated, not so much for purposes of valuation as in order to 'be assured that a separate item has actually been dealt with, the [amount paid for 'the] agreement is ordinary income and not the sale of a capital asset. Estate of Mildred, K. Hyde, 42 B.T.A. 738 . But where it accompanies the transfer of good will in the sale of a going business and it is apparent that the covenant not to compete has the function primarily of assuring to the purchaser the 'beneficial enjoyment of the good will which he has acquired, the covenant is regarded as nonseverable and as being in effect a contributing element to the assets transferred. Toledo Newspaper Co., 2 T.C.794; Toledo Blade Co., 11 T.C. 1079 .”
2 later decisions quote this exact passage
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.