Parker v. Delaney’s Empirical Analysis
186 F.2d 455 · 1950
Citation profile
18 federal appellate ·
How this case has been cited
Cited by 50 later decisions — most recently April 2001 · most notably Siegel v. Commissioner (1982), Waddell v. Commissioner (1986)
18 federal appellate ·
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. § 111 · 26 U.S.C. § 117
Relies on Crane v. Commissioner · Detroit Edison Co. v. Commissioner · Virginian Hotel Corporation of Lynchburg v. Helvering · Commissioner v. Hoffman
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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Computation of gain or loss. — The gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis provided in-section 1011 for determining gain, and the loss shall be the excess of the adjusted basis provided in such section for determining loss over the amount realized. (c) Recognition of gain or loss. — In the case of a sale or exchange of property, the extent to which the gain or loss determined under this section shall be recognized for purposes of this subtitle shall be determined under section 1002. § 1002. Recognition of gain or loss. Except as otherwise provided in this subtitle, on the sale or exchange of property the entire amount of the gain or loss, determined under section 1001, shall be recognized.”
2 later decisions quote this exact passage · from the majority“Obviously, if the value of the property is less than the amount of the mortgage, a mortgagor who is not personally liable cannot realize a benefit equal to the mortgage. Consequently, a different problem might be encountered where a mortgagor abandoned the property or transferred it subject to the mortgage without receiving boot. That is not this case.”
2 later decisions quote this exact passage · from the majority“§ 111. Determination of amount of, and recognition of, gain or loss * * * * * "(b) Amount realized. The amount realized from the sale or other disposition of property shall be the sum of any money received plus the fair market value of the property (other than money) received.”
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.