Heebner v. Commissioner’s Empirical Analysis
1960
Citation profile
18 federal appellate ·
How this case has been cited
Cited by 33 later decisions — most recently November 1997 · most notably Missouri Pacific Railroad v. Austin (1961), Pleasant Summit Land Corp. v. Commissioner (1988)
18 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
Applies 26 U.S.C. § 117
Relies on Corn Products Refining Company v. Commissioner of Internal Revenue · Erie Railroad v. Board of Public Utility Commissioners of New Jersey · Kaltreider v. Commissioner · The Pennroad Corporation and Affiliated Companies v. Commissioner of Internal Revenue
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““where the ultimate fact reasonably flows from the basic facts and especially where the basic facts are persuasive of the ultimate fact so found, this court will not disturb the finding of the trial court.” Pennroad Corp. v. Commissioner of Internal Revenue, supra, 261 F.2d at 328 .”
3 later decisions quote this exact passage · from the majority“held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business.”
2 later decisions quote this exact passage · from the majority“There is absolutely no reason for treating the profit from the building transaction here any differently because one small aspect of it involved a sale of land. The land under this factual pattern was merely another commodity, such as lumber, steel and bricks, which went into the finished product * * *.”
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.