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← 3 TC 342 - Kramon Development Co. v. Commissioner

Kramon Development Co. v. Commissioner’s Empirical Analysis

1944

Citation profile

5
cited by 5 later decisions
1
cited 1 times by the Supreme Court
April 2007
most recently cited

How this case has been cited

Cited by 5 later decisions (1 by the Supreme Court) — most recently April 2007

101944195019601970198019902000decided

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 United States v. Kirby Lumber Co. · Helvering v. American Dental Co. · Helvering v. American Chicle Co. · Lakeland Grocery Co. v. Commissioner · Artcraft Silk Hosiery Mills, Inc. v. Gotham Silk Hosiery Co.

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

  1. “The discrepancy between the value of the property as we have found it and the face value of the bonds raises the question whether the latter were issued at par within the meaning of respondent’s regulations. See Sacramento Medico Dental Building Co., 47 B. T. A. 315; cf. American Smelting & Refining Co. v. United States (C. C. A., 3d Cir.), 130 Fed. (2d) 883. But, if not, the Kirby case offers no guidance. Its reliance on the regulations, e. g., Regulations 62, art. 645, see Regulations 101, art. 22 (a) (18), demonstrates the area in which its operation was intended to be confined, and indicates that the difference between purchase price and face value is significant only where there is no discount upon issuance. See Terminal Investment Co., 2 T. C. 1004, 1013 . We have consistently taken this view and emphasized the issue price rather than par value in computing gain from the discharge of obligations. * * *”
    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.