Commissioner v. Tri-S Corp.’s Empirical Analysis
1968
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 28 later decisions — most recently April 1984 · most notably Suburban Realty Company v. United States (1980), McManus v. Commissioner (1975)
12 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
Relies on Friend v. Commissioner · Coffey 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“For purposes of this subtitle, the term “capital asset’’ means property held by the taxpayer (whether or not connected with his trade or business), but does not include— (1) stock in trade of the taxpayer or other property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year, or property held by the taxpayer primarily for sale to customers in the ordinary course of his trade or business;”
7 later decisions quote this exact passage · from the majority““After the petitioner was notified by the state that 16.5 acres of the 100 acre tract held by the petitioner were subject to condemnation, the petitioner was not holding that portion of the tract ‘primarily for sale to customers in the ordinary course of his trade or business’ within the meaning of section 1221(1). The 16.5 acre portion of the tract was a capital asset at the time of its sale to the state.””
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.