Pickren v. United States’s Empirical Analysis
378 F.2d 595 · 1967
Citation profile
8 federal appellate · 2 state decisions
How this case has been cited
Cited by 36 later decisions — most recently February 2019 · most notably Green v. Comm'r (1984), PPG Indus., Inc. v. Commissioner (1970)
8 federal appellate · 2 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. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Commissioner of Internal Revenue v. P G Lake · Smith v. Dravo Corp. · E. W. Bliss Co. v. United States · E. I. Du Pont De Nemours & Co. v. United States · Aktiebolaget Bofors 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The cardinal rule in the interpretation of contracts is to ascertain the mutual intention of the parties and then, so far as it is possible so to do consistently with legal principles, give effect to that intention. * * *”
3 later decisions quote this exact passage · from the majority“[a] transfer . . . of property consisting of all substantial rights to a patent . . . by any holder shall be considered the sale or exchange of a capital asset held for more than 1 year.”
3 later decisions quote this exact passage · from the majority“[s]ecret formulas and trade names are sufficiently akin to patents to warrant the application, by analogy, of the tax law that has been developed relating to the transfer of patent rights, in tax cases involving transfers of secret formulas and trade names.”
2 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.