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← 25 TCM 479 - Hegra Note Corp. v. Commissioner

Hegra Note Corp. v. Commissioner’s Empirical Analysis

1966

Citation profile

2
cited by 2 later decisions
May 1971
most recently cited

Relationships

Applies 26 U.S.C. § 368 · 26 U.S.C. § 453

Relies on Mayer v. Donnelly · Bonham v. Commissioner of Internal Revenue · Bonham v. Commissioner · Stoody Co. v. Mills Alloys, Inc. · Thos. Goggan & Bro. 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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““If installment notes were transferred for so nebulous a right that nothing with an ascertainable fair market value might be said to have been received therefor, it would be questionable whether an exchange as distinguished from other disposition of the notes had occurred within the meaning of section 453(d) (1). The clear import of the statute is that upon disposition in any manner of installment obligations, other than certain tax free exchanges, the portion of the gain deferred when the installment method of reporting the gain was elected which has not previously been included in income becomes includable therein.’'”
    2 later decisions 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.