Commissioner v. Korell’s Empirical Analysis
339 U.S. 619 · 1950
Citation profile
44 federal appellate · 9 district · 6 state decisions
How this case has been cited
Cited by 120 later decisions (13 by the Supreme Court) — most recently June 1987 · most notably James v. United States (1961), Commissioner v. Brown (1965)
44 federal appellate · 9 district · 6 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.
Appellate journey
reviewedCommissioner v. Korell (from Second Circuit Court of Appeals)
Relationships
Relies on Crane v. Commissioner · Old Colony Co v. Commissioner of Internal Revenue · Helvering v. San Joaquin Fruit & Investment Co. · Helvering v. William Flaccus Oak Leather Co. · New York Life Insurance v. Edwards
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 120 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Amortizable Bond Premium. (a) General rule. — In the case of any bond, as defined in subsection (d) the following rules shall apply to the amortizable bond premium (determined under subsection (b)) on the bond for any taxable year beginning after December 31, 1941: (1) Interest wholly or partially taxable. — In the case of a bond (other than a bond the interest on which is excludible from gross income), the amount of the amortizable bond premium for the taxable year shall be allowed as a deduction. * * * * # (b) Amortizable bond premium.- — ■ (1) Amount of bond premium.— Eor the the purposes of paragraph (2), the amount of bond premium, in the case of the holder of any bond, shall be determined with reference to the amount of the basis (for determining loss on sale or exchange) of such bond, and with reference to the amount payable on maturity or on earlier call date, with adjustments proper to reflect unamortized bond premium with respect to the bond, for the period prior to the date as of which subsection (a) becomes applicable with respect to the taxpayer with respect to such bond.” s * * * *”
3 later decisions quote this exact passage · from the majority“the amount of the bond premium attributable to such year,”
3 later decisions quote this exact passage · from the majority“(A) in accordance with the method of amortizing bond premium regularly employed by the holder of the bond, if such method is reasonable;”
2 later decisions quote this exact passage · from the majoritye.g. Estate of A. Gourielli, Deceased, the Hanover Bank, and Helena Gourielli, Surviving Wife v. Commissioner of Internal Revenue, Jacob A. And Bertha L. Goldfarb v. Commissioner of Internal Revenue · Estate of A. Gourielli, Deceased, the Hanover Bank, and Helena Gourielli, Surviving Wife v. Commissioner of Internal Revenue, Jacob A. And Bertha L. Goldfarb v. Commissioner of Internal Revenue
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.