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← 2 BTA 555 - Clark v. Commissioner

Clark v. Commissioner’s Empirical Analysis

1925

Citation profile

19
cited by 19 later decisions
November 1989
most recently cited

How this case has been cited

Cited by 19 later decisions — most recently November 1989

1201925193019401950196019701980decided

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 Fouke v. Commissioner · Dobson v. Commissioner · Pennsylvania Co. v. Commissioner · Britt v. Commissioner · Bradley 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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “* * * The payment of a price and the delivery of certificates do not constitute the sole requisite of a valid sale. The parties must make a bona fide transfer as persons dealing at arm’s length would do — the seller for the purpose of absolutely getting rid of the stock and the buyer for the purpose of absolutely acquiring it as his own without any condition covering its later return to the seller. Receiving a credit for the price and the mere indicia of ownership without the mutual element of intent on both sides to complete an absolute .sale, can not constitute a basis for a deduction for loss under the provisions of the tax law. A loss to be deductible must be a reality. [Emphasis supplied.]”
    1 later decision 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.