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Jones v. Corbyn’s Empirical Analysis

186 F.2d 450 · 1950

Citation profile

77
cited by 77 later decisions
2
states following
August 2016
most recently cited

38 federal appellate · 2 district · 3 state decisions

How this case has been cited

Cited by 77 later decisions — most recently August 2016 · most notably Commissioner v. Ferrer (1962), Commissioner v. Starr Bros. (1953)

38 federal appellate · 2 district · 3 state decisions

3501950196019701980199020002010decided

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. § 117 · 26 U.S.C. § 22

Relies on Lyeth v. Hoey · Hort v. Commissioner · Lynch v. Alworth-Stephens Co. · Helvering v. Safe Deposit & Trust Co. · Grace Bros. v. Commissioner of Internal Revenue

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 77 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “should be taxed as a long-term capital gain or as ordinary income. The answer to this question depends upon a precise analysis of the rights and interests then existing between the parties. 32 In 1944 Russell held a lease on certain real estate in Pike County, Kentucky. In order to enable it to install a coal mining plant thereon Pittston, pursuant to a contract with Russell dated January 25, 1944, agreed to loan Russell $250,000 to be advanced in such amounts as required for”
    1 later decision quote this exact passage · from the majority
  2. “The contract or franchise had at all times substantial value. It was capable of producing income for its owner. It was enforceable at law and could be bought and sold”
    1 later decision quote this exact passage · from the majority
  3. “By terminating the contract and transferring the business to the company, there was a sale and transfer of a capital asset within the meaning of the statute”
    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.