Alderson v. Commissioner’s Empirical Analysis
1963
Citation profile
18 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 58 later decisions — most recently August 2016 · most notably Starker v. United States (1979), June Pinson Carlton and Charles T. Carlton, as Administrators of the Estate of Thad H. Carlton, and June Carlton v. United States (1967)
18 federal appellate · 1 district · 4 state decisions
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. § 1002
Relies on Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Schulz v. Commissioner · Mercantile Trust Co. 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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Nonrecognition oe Gain ok Loss From Exchanges Sodelx in Kind. — No gain or loss shall be recognized if property held for productive use in trade or business or for investment (not including stock in trade or other property held primarily for sale, nor stocks, bonds, notes, ohoses m action, certificates of trust or beneficial interest, or other securities or evidences of indebtedness or interest) is exchanged solely for property of a like kind to be held either for productive use in trade or business or for investment. [Emphasis supplied. ]”
3 later decisions quote this exact passage · from the majority“[for] the purpose of the exchange ... there was no need for [the accommodator] to acquire a “real” interest in the ... property by assuming the benefits and burdens of ownership to make the exchange qualify under the statute.... [One] need not assume the benefits and burdens of ownership in property before exchanging it but may properly acquire title solely for the purpose of exchange and accept title and transfer it in exchange for other like property....”
1 later decision quote this exact passage · from the majority“to deed the Salinas property to Alloy, provided Salinas Title could 'immediately record a deed from Alloy * * * to James Alderson and Clarissa E. Alderson, his wife [the taxpayers], issuing final title evidence in the last mentioned grantees.'”
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.