Warren Jones Co. v. Commissioner’s Empirical Analysis
524 F.2d 788 · 1975
Citation profile
14 federal appellate · 1 district ·
How this case has been cited
Cited by 39 later decisions — most recently December 2019 · most notably Estate of Charles T. Franklin, Deceased v. Commissioner of Internal Revenue (1976), McShain v. Commissioner (1979)
14 federal appellate · 1 district ·
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. § 1001 · 26 U.S.C. § 453
Relies on Commissioner of Internal Revenue v. South Texas Lumber Co · Burnet v. Logan · United States v. Davis · Gersten v. Commissioner · Bedell 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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis.”
2 later decisions quote this exact passage · from the majority“plus the fair market value of the property (other than money) received.”
2 later decisions quote this exact passage · from the majority“(3) PAYMENT. — Except as provided in paragraph (4), the term “payment” does not include the receipt of evidences of indebtedness of the person acquiring the property (whether or not payment of such indebtedness is guaranteed by another person). (4) Purchaser evidences of indebtedness payable on demand or READILY TRADABLE. — Receipt of a bond or other evidence of indebtedness which (A) is payable on demand, or (B) is issued by a corporation or a government or political subdivision thereof and is readily tradable, shall be treated as receipt of payment. (5) READILY tradable defined. — For purposes of paragraph (4), the term “readily tradable” means a bond or other evidence of indebtedness which is issued— (A) with interest coupons attached or in registered form (other than one in registered form which the taxpayer establishes will not be readily tradable in an established securities market), or (B) in any other form designed to render such bond or other evidence of indebtedness readily tradable in an established securities market.”
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.