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← 50 TC 203 - Nye v. Commissioner

Nye v. Commissioner’s Empirical Analysis

1968

Citation profile

23
cited by 23 later decisions
June 2015
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 23 later decisions — most recently June 2015

2 federal appellate ·

110196819701980199020002010decided

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

Relies on Commissioner of Internal Revenue v. Court Holding Co · Citizens Bank & Trust Co. v. United States · Pinellas Ice & Cold Storage Co. v. Commissioner · Guth v. Loft, Inc. · Ritter v. United States

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.

  1. “(a) General Rule. — No gain or loss shall be recognized if property is transferred to a corporation * * * by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation.”
    1 later decision quote this exact passage · from the majority
  2. “To provide a basis for such deductions the “covenant must have some independent basis in fact or some arguable relationship with business reality such that reasonable men, genuinely concerned with their economic future, might bargain for such an agreement.””
    1 later decision quote this exact passage · from the majority
  3. “the payment of indebtedness usually depends to a large extent upon the success of the obligor.”
    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.