Commissioner of Internal Revenue v. Estate of Ralph W. Simmers, Deceased, Mary E. Simmers, and Mary E. Simmers (Surviving Wife), Commissioner of Internal Revenue v. Ralph W. Simmers and Son, Incorporated’s Empirical Analysis
1956
Citation profile
11 federal appellate · 1 state decisions
How this case has been cited
Cited by 22 later decisions — most recently March 1984
11 federal appellate · 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
Applies 26 U.S.C. § 111
Relies on Gregory v. Helvering · Helvering v. Alabama Asphaltic Limestone Co. · Consumers' Ice Co. v. William H. H. Bixler & Co. · Moran v. Hammersla · Mary Lucinda Bosley v. Margaret E. Wyatt
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“While the economic relation between lessor and lessee resembles that of mortgagor and mortgagee, there is the important difference that the purchaser can never be compelled to pay the so-called mortgage debt. Ordinarily, a vendor-mortgagee receives something of value in exchange for the transfer of the land, that is, the obligation of the vendee-mortgagor, which in Maryland is usually in the form of a note, to pay a definite sum at a fixed time in the future. But the vendor in the ground rent system holds no such obligation and can recover the principal sum only by the voluntary redemption of the rent by the vendee or a sale of the rent to a third party. The difference is vital because there is no realization of taxable gain until one or the other of these events occurs.”
1 later decision quote this exact passage · from the majority“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.