Paragon Jewel Coal Company v. Commissioner of Internal Revenue’s Empirical Analysis
1965
Citation profile
75 federal appellate · 9 district · 4 state decisions
How this case has been cited
Cited by 199 later decisions (8 by the Supreme Court) — most recently July 2016 · most notably In re Thirteen Appeals Arising Out of the San Juan Dupont Plaza Hotel Fire Litigation (1995), First National Bank of Smithfield, North Carolina v. James J. Saxon, Comptroller of the Currency of the United States, First National Bank of Smithfield, North Carolina v. First National Bank of Eastern North Carolina (1965)
75 federal appellate · 9 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.
Appellate journey
reviewedMerritt v. Commissioner (from Fourth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 611 · 26 U.S.C. § 631
Relies on County of Allegheny v. Frank Mashuda Co. · Ragan v. Merchants Transfer & WareHouse Co. · Palmer v. Bender · Commissioner v. Southwest Exploration Co. · Thomas v. Perkins
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 199 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“were completely terminable without cause on short notice”
7 later decisions quote this exact passage · from the majority“a mere economic advantage derived from production, through a contractual relation to the owner, by one who has no capital investment in the mineral deposit.”
6 later decisions quote this exact passage · from the majority““The parties agree that the principles of our opinion in Parsons v. Smith, 359 U.S. 215 , 79 S.Ct. 656 , 3 L.Ed.2d 747 (1959), are controlling here. There we held that the deduction is allowed in recognition of the fact that mineral deposits are wasting assets and that the deduction is intended as compensation to the owner for the part used in production; that there may be more than one depletable interest in the same coal deposit, but that the right to an allocable portion of the allowance depends on the ownership of an economic interest in the coal in place since the statute makes the deduction available only to the owner of a capital interest in such deposit; and, finally, that the legal form of such capital interest is unimportant so long as it constitutes a right with regard to the coal in place.””
5 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.