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← 47 TC 340 - Mayerson v. Commissioner

Mayerson v. Commissioner’s Empirical Analysis

1966

Citation profile

111
cited by 111 later decisions
March 2012
most recently cited

6 federal appellate · 1 district ·

How this case has been cited

Cited by 111 later decisions — most recently March 2012 · most notably Petzoldt v. Commissioner (1989), Brannen v. Commissioner (1984)

6 federal appellate · 1 district ·

460196619701980199020002010decided

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 · 26 U.S.C. § 178

Relies on Crane v. Commissioner · Weiss v. Wiener · Parker v. Delaney · Gladding Dry Goods Co. v. Commissioner · Standard Oil Co. 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 111 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “There were only two variables in the overall purchase price of the property, and they were specified in dollar amounts. The price depended then upon whether the purchase-money mortgage was paid within the first year, the second year, or years thereafter. We would classify such a price reduction for early payment as a bonus discount. The presence of such optional discounts does not make the purchase price indefinite. It merely provided an incentive for very early retirement of the mortgage which did not occur. The cost basis at the time of purchase should be the nondiscount price; the entire principal of the note and mortgage was due unless the discounted sums were paid in the first 2 years. It was not prepaid so as to provide for the application of the discount provisions and hence no adjustment in basis is required during the years before us. * * * [Emphasis supplied.]”
    1 later decision quote this exact passage · from the majority
  2. “to give the taxpayer an advance credit for the amount of the mortgage. This appears to be reasonable, since it can be assumed, that a capital investment in the amount of the mortgage will eventually occur despite the absence of personal liability. * * * [See 47 T.C. at 352 . Emphasis added.]”
    1 later decision quote this exact passage
  3. “The essential purpose of a deficiency notice is to provide a formal notification that a deficiency in taxes has been determined.”
    1 later decision 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.