Clodfelter v. Commissioner’s Empirical Analysis
1970
Citation profile
17 federal appellate ·
How this case has been cited
Cited by 59 later decisions — most recently January 2020 · most notably Estate of Charles T. Franklin, Deceased v. Commissioner of Internal Revenue (1976), Baird v. Commissioner (1977)
17 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
Applies 26 U.S.C. § 1001 · 26 U.S.C. § 7482
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Burnet v. Logan · Commissioner of Internal Revenue v. Union Pac. R. Co. · Commissioner v. Segall
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“There are no hard and fast rules of thumb that can be used in determining, for taxation purposes, when a “sale” was consummated, and no single factor is controlling, but transaction must be viewed as a whole and in the light of realism and practicality, * * *”
2 later decisions quote this exact passage · from the majority“we do not feel that the single fact of a 'no recourse' clause served to delay the finality of this sale until final payment of the total purchase price had been made.”
1 later decision 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.