Poyner v. Commissioner’s Empirical Analysis
1962
Citation profile
41 federal appellate · 4 district ·
How this case has been cited
Cited by 65 later decisions — most recently April 2017 · most notably Olk v. United States (1976), Smith v. Commissioner (1962)
41 federal appellate · 4 district ·
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. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Bogardus v. Commissioner · United States v. Kaiser · Simpson v. United States
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 65 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) [T]he payments had been made to the wife of the deceased employee and not to his estate; (2) there was no obligation on the part of the corporation to pay any additional compensation to the deceased employee; (3) the corporation derived no benefit from the payment; (4) the wife of the deceased employee performed no services for the corporation; and (5) the services of her husband had been fully compensated.”
5 later decisions quote this exact passage“(a) General rule. — Gross income does not include the value of property acquired by gift, * * *.”
4 later decisions quote this exact passage“On the other hand, Duberstein cannot be read as limiting inquiry by the trier of fact solely to the factors recognized by the earlier decisions. The objective is to discover which motive is dominant in a field of co-existing motives. In the task of sorting out the varying motives, the development of more reliable criteria by the triers of fact should not be curtailed. Indeed, the Tax Court since Duberstein has considered it necessary to inquire into the widow’s stock holdings in the company and the knowledge or lack of it on the part of the Board of her financial status following the death of her husband. The Tax Court in the present ease also seems to have thought that the directors’ knowledge of “the widow’s needs” was an important factor. These subjects are certainly relevant, and inquiry may properly be directed to them, and whatever other factors the trier of fact might think helpful.”
3 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.