Kolom Et Ux. v. Commissioner of Internal Revenue’s Empirical Analysis
1981
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 23 later decisions (1 by the Supreme Court) — most recently January 2014
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
Applies 15 U.S.C. § 78P (§ 16 of the Securities Exchange Act of 1934) · 26 U.S.C. § 421 · 26 U.S.C. § 56 · 26 U.S.C. § 57 · 26 U.S.C. § 83
Relies on Blue Chip Stamps v. Manor Drug Stores · Reiter v. Sonotone Corp. · United States v. Cartwright · Helvering v. Tex-Penn Oil Co. · Hopper v. Johnson
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(а) In General — For purposes of this part, the items of tax preference are— (б) Stock Options — With respect to the transfer of a share of stock pursuant to the exercise of a qualified stock option (as defined in section 422(b)) or a restricted stock option (as defined in section 424(b)), the amount by which the fair market value of the share at the time of exercise exceeds the option price.”
1 later decision quote this exact passage · from the dissent“the fair market value of a share of stock shall be determined [for minimum tax purposes] without regard to any restriction other than a restriction which, by its terms, will never lapse.”
1 later decision quote this exact passage · from the dissent“the failure to include any similar qualification in Sec. 57 strongly suggests that [Congress] intended to use 'fair market value' in its traditional and well-established sense.”
1 later decision quote this exact passage · from the dissent
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.