Boe v. Commissioner’s Empirical Analysis
1961
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 48 later decisions — most recently June 2014 · most notably IT&S of Iowa, Inc. v. Commissioner (1991), Westinghouse Broadcasting Co. v. Commissioner (1961)
1 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. § 167 · 26 U.S.C. § 23
Relies on Thrifticheck Service Corp. v. Commissioner · Houston Natural Gas Corp. v. Commissioner of Internal Revenue · Danville Press, Inc. v. Commissioner · Metropolitan Laundry Co. v. United States · Meredith Pub. 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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Petitioner presents a variation on a rather settled theme. The courts have on numerous occasions held that subscription lists and similar items constituted a single capital asset, and as such continued to have value despite fluctuations and alterations. Thrifticheck Service Corporation, 33 T.C. 1038 (1960), on appeal (C.A. 2); Metropolitan Laundry Co. v. United States, 100 F. Supp. 803 (N.D. Cal. 1951). These decisions involved newspaper subscription lists, The Danville Press, Inc., 1 B.T.A. 1171 (1925); magazine circulation structures, Meredith Pub. Co. v. Commissioner, 64 F. 2d 890 (C.A. 8, 1933); insurance policyholders, Commercial National Insurance Co., 12 B.T.A. 655 (1928); natural gas consumers, Houston Natural Gas Corp. v. Commissioner, 90 F. 2d 814 (C.A. 4, 1937); cleaning service customers, Anchor Cleaning Service, Inc., 22 T.C. 1029 (1954); and contracts of cheeking account system customers, Thrifticheck Service Corporation, supra. Petitioner has shown us nothing to indicate that the contracts here in issue were not a collective, single asset. In fact, the record is most persuasive that they were. * * *”
1 later decision quote this exact passage“that the acquisition of these contracts constituted the acquisition of but one intangible capital asset which is not exhausted by the passage of time alone, but has such a characteristic of continuing value and useful life that it cannot bear amortization.”
1 later decision quote this exact passage“Petitioner has shown us nothing to indicate that the contracts here in issue were not a collective, single asset.”
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.