Hirsch v. Commissioner’s Empirical Analysis
1968
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 23 later decisions — most recently May 2004
7 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. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Austin v. Smith · Smith v. Commissioner of Internal Revenue · Sloane v. Commissioner · Farr v. Commissioner · Helton 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.
“(2) (i) If the option is exercised by the person to whom it was granted but, at the time an unconditional right to receive the property subject to the option is acquired by such person, such property is subject to a restriction which has a significant effect on its value, the employee realizes compensation at the time such restriction lapses or at the time the property is sold or exchanged, in an arm’s length transaction, whichever occurs earlier, * * * •”
3 later decisions quote this exact passage“upon the terms and conditions of the option.”
2 later decisions quote this exact passage“Since neither Ira’s circumstances nor the Securities Act of 1933 changed materially if at all from July 3, 1961, the date he exercised the options, to February 1,1962, or thereafter, we conclude that the SEC would have issued a similar ruling if the request had been made on July 3,1961, when the option was first exercised. Even if we were to assume that a sale of Ira’s shares would not have violated the 1933 Act, the SEC’s position that it would consider any sale without prior registration as a violation is a restriction which has a significant effect on the value of the stock.”
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.