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← 279 F.2d 220 - American Natural Gas Co. v. United States

American Natural Gas Co. v. United States’s Empirical Analysis

279 F.2d 220 · 1960

Citation profile

13
cited by 13 later decisions
May 1986
most recently cited

4 federal appellate · 1 district ·

How this case has been cited

Cited by 13 later decisions — most recently May 1986

4 federal appellate · 1 district ·

80196019701980decided

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 15 U.S.C. § 79 (Public Utility Holding Company Act of 1935) · 26 U.S.C. § 112 · 26 U.S.C. § 117

Relies on Mugler v. State of Kansas State of Kansas Tufts · American Power & Light Co. v. Securities & Exchange Commission · Union Bridge Company v. United States · United States v. Central Eureka Mining Co. · North American Co. v. Securities & Exchange Commission

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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Plaintiffs say that the term “requisition or condemnation” as used in the Act means something more than the exercise of the power of eminent domain. We do not think it does. It seems clear to us that the words mean the taking or the threat of taking property by some public or quasi-public corporation — by some instrumentality that has the power to do so against the will of the owner, and for the use of the taker. That is the common, well-recognized meaning of those words and there is nothing to indicate that Congress used them in any other sense. Plaintiffs were required to dispose of their property, but the United States did not take it, nor did it prevent plaintiffs from getting for it its full market value at the time of the taking.”
    2 later decisions quote this exact passage
  2. “(a) General Rule. Upon the sale or exchange of property the entire amount of the gain or loss, determined under Section 111, shall be recognized, except as hereinafter provided in this section. * * * * “(f) [As amended by Sec. 1, Act of October 31, 1951, c. 661, 65 Stat. 733 .] Involuntary Conversion. If property (as a result of its destruction in whole or in part, theft, seizure, or requisition or condemnation or threat or imminence thereof) is compulsorily or involuntarily converted— “(1) Conversion into similar property. Into property similar or related in service or use to the property so converted, no gain shall be recognized. “(2) Conversion into money where disposition occurred prior to 1951. * * * For the purposes of this paragraph and paragraph (3), the term ‘disposition of the converted property’ means the destruction, theft, seizure, requisition, or condemnation of the converted property, or the sale or exchange of such property under threat or imminence of requisition or condemnation. “(3) Conversion into money ivhere disposition occurred after 1950. Into money or into property not similar or related in service or use to the converted property, and the disposition of the converted property (as defined in paragraph (2)) occurred after December 31, 1950, the gain (if any) shall be recognized except to the extent hereinafter provided in "this paragraph: “(A) Nonrecognition of Gain. If the taxpayer during the period specified in subparagraph (B), for the purpose of re”
    1 later decision quote this exact passage
  3. “SEC. 1231(a). General Rule. — If, during the taxable year, the recognized gains on sales or exchanges of property used in the trade or business, plus the recognized gains from the compulsory or involuntary conversion (as a result of destruction in whole or in part, theft or seizure, or an exercise of the power of requisition or condemnation or the threat or imminence thereof) of property used in the trade or business and capital assets held for more than 6 months [9 months in 1977] into other property or money, exceed the recognized losses from such sales, exchanges, and conversions, such gains and losses shall be considered as gains and losses from sales or exchanges of capital assets held for more than 6 months [9 months in 1977]. If such gains do not exceed such losses, such gains and losses shall not be considered as gains and losses from sales or exchanges of capital assets. * * *”
    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.