Travis v. Commissioner’s Empirical Analysis
1967
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 16 later decisions — most recently June 2015
2 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. § 166
Relies on Spring City Foundry Co. v. Commissioner · Commissioner v. Hansen · Schlude v. Commissioner of Internal Revenue · Pacific Nat Co v. Welch · Caldwell v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Caldwell
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It should be noted, however, that we have treated this aspect of the case as though the petitioner and the corporation, which elected subchapter S treatment for the year in issue, were the same taxable entity. This was the approach taken in E. Morris Cox, supra, [ 22 ] and seems sound in light of the purposes of subchapter S. If the corporation had not elected subchapter S treatment, the cash received by it with respect to accounts transferred to it by the sole proprietorship would have been includable in its income for 1958. This is because the accounts were transferred from the sole proprietorship in a tax-free exchange. The corporation therefore had the same basis in them as the sole proprietorship, which had a basis of zero. Therefore, if the corporation were a separate taxable entity it would have been required to take into income all cash received with respect to such accounts. P.A. Birren & Son v. Commissioner, 116 F.2d 718 (C.A. 7, 1940), and cf. Ezo Products Co., 37 T.C. 385 (1961).”
1 later decision quote this exact passage“I. Did a corporation that entered into executory contracts to teach lessons to its students in exchange for cash to be paid in installments have a legally enforceable right under Michigan law to receive the full amount of each installment when it became due if the corporation had not yet performed the services for which the installment was the consideration? 4 "II. Did a method of accounting that had been imposed by the respondent upon a predecessor partnership that owned and operated the same business as that owned and operated by the corporation, and that had been upheld by the Tax Court when challenged by one of the partners, clearly reflect the income of the corporation? 5 "III. If the installment payments under the student enrollment agreements are to be included in income, is the corporation entitled to a deduction for a reasonable addition to its reserve for bad debts in 1958 for more than $16,483.54?”
1 later decision quote this exact passage“I. Did a corporation that entered into executory contracts to teach lessons to its students in exchange for cash to be paid in installments have a legally enforceable right under Michigan law to receive the full amount of each installment when it became due if the corporation had not yet performed the services for which the installment was the consideration? 4”
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.