Haggard v. Commissioner’s Empirical Analysis
1955
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 68 later decisions — most recently November 2012 · most notably Grodt & McKay Realty, Inc. v. Commissioner (1981), Falsetti v. Commissioner (1985)
4 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
Relies on Benton v. Commissioner · Holeproof Hosiery Co. v. Commissioner · Mills v. Commissioner · Bowen v. Commissioner · Chicago Stoker 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 68 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * To properly discern the true character of the payment, therefore, it is necessary to ascertain the intention of the parties as evidenced by the written agreements, read in the light of the attending facts and circumstances existing at the time the agreement was executed.”
3 later decisions quote this exact passage“* * * The precise problem posed of characterizing a payment made pursuant to a lease-option arrangement has been before this Court on numerous occasions, and regardless of the form or nomenclature of the transaction, we have treated similar 'rental' payments as partial payments of the purchase price of the property involved, if by virtue of the payment the taxpayer has acquired, or will acquire title to or an equity in the property. Alexander W. Smith, Jr., Executor, 20 B.T.A. 27 (1930) ; Chicago Stoker Corporation, 14 T.C. 441 (1950) . The principle extending throughout the cases heretofore decided by us on like issues is that where the 'lessee' as a result of the 'rental' payment, acquires something of value in relation to the over-all transaction, other than the mere use of the property, he is building up an equity in the property, and the payments do not, therefore, come within the definition of rent in section 23(a)(1)(A) , supra. Judson Mills, 11 T.C. 25 (1948) ; Truman Bowen, 12 T.C. 446 (1949) . "* * * To properly discern the true character of the payment, therefore, it is necessary to ascertain the intention of the parties as evidenced by the written agreements, read in the light of the attending facts and circumstances existing at the time the agreement was executed.”
1 later decision quote this exact passage“to which the taxpayer has not taken or is not taking title or in which he has no equity.”
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.