General Insurance Agency, Inc. v. Commissioner of Internal Revenue’s Empirical Analysis
401 F.2d 324 · 1968
Citation profile
8 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 39 later decisions — most recently January 2020 · most notably Major v. Commissioner (1981), Forward Communications Corp. v. United States (1979)
8 federal appellate · 2 district · 1 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. § 167
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Duberstein D Stanton · Helvering v. Taylor · Ullman v. Commissioner · Schulz 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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he determination of whether a part of the purchase price represents payment for a non capital item, i.e., a covenant not to compete, depends upon whether the parties to the agreement intended to allocate a portion of the purchase price to such covenant at the time they executed their formal sales agreement. It is necessary also to establish that the covenant “have some independent basis in fact or some arguable relationship with business reality such that reasonable men, genuinely concerned with their economic future, might bargain for such an agreement.””
6 later decisions 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.