Commissioner of Internal Revenue v. P G Lake’s Empirical Analysis
1958
Citation profile
539 federal appellate · 15 district · 17 state decisions
How this case has been cited
Cited by 1,055 later decisions (22 by the Supreme Court) — most recently May 2019 · most notably Frank Lyon Co. v. United States (1978), Golsen v. Commissioner (1970)
539 federal appellate · 15 district · 17 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. P. G. Lake, Inc. (from Fifth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 117
Relies on Helvering v. Clifford · Helvering v. Horst · Burnet v. Harmel · Corn Products Refining Company v. Commissioner of Internal Revenue
Cited together with Corn Products Refining Company v. Commissioner of Internal Revenue · Hort v. Commissioner · Commissioner v. Gillette Motor Transport, Inc. · Helvering v. Horst · Gregory v. Helvering
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 1,055 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“essentially a substitute for what would otherwise be received at a future time as ordinary income.”
30 later decisions quote this exact passage · from the majority“gain from the sale or exchange of a capital asset”
7 later decisions quote this exact passage · from the majority“The purpose of § 117 (of the Internal Revenue Code of 1939, pertaining to taxation of capital gains) was `to relieve the taxpayer from * * * excessive tax burdens on gains resulting from a conversion of capital investments, and to remove the deterrent effect of those burdens on such conversions.' (citation omitted). And this exception has always been narrowly construed so as to protect the revenue against artful devices.”
4 later decisions 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.