Juleo, Inc., a New Jersey Corporation v. Commissioner of Internal Revenue’s Empirical Analysis
1973
Citation profile
14 federal appellate ·
Relationships
Applies 26 U.S.C. § 1221
Relies on Consolidated Edison Co. of New York v. United States · Malat v. Riddell · Erie Railroad v. Board of Public Utility Commissioners of New Jersey · Kaltreider v. Commissioner · Stockton Harbor Industrial 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[If] there had been no condemnation, the land which was part of the development would have been sold as such and the proceeds treated as ordinary business income. When the condemnation took place, the owner sought to establish a value, for purposes of the condemnation award, that reflected what the owner would have received if the land had been sold as developed. Consequently, to treat the income actually received, which in large part reflected the intent and plan of the owner, as capital gains rather than ordinary income would appear to be inequitable.”
2 later decisions quote this exact passage · from the majority“After [the taxpayer] received what it considered to be a threat of condemnation in September 1964, its officers realized that it would be futile to hold the land any longer for eventual residential development; their original objective in holding [the property] had to be abandoned and thereafter the land was held primarily for speculation and investment. . By the time of the disposition of the land in question in the latter part of 1965 and 1966, [the taxpayer’s] purpose with regard to [the property] had been so altered by circumstances beyond its control that the character of the land could no longer be considered within section 1221(1), ., [the property] was no longer held “for sale to customers in the ordinary course of * * * business."”
1 later decision quote this exact passage · from the majority“We regard the holding of the Tri-S Corp. case as determinative of the issue now before us. After the condemnation notice in this case, petitioner no longer held the 16.5 acre tract primarily for sale to customers in the ordinary course of its trade or business, and the property sold to the State of New Jersey was a capital asset at the time of its sale.”
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.