Hassen v. Commissioner’s Empirical Analysis
1979
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 14 later decisions — most recently October 1999
4 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. § 267
Relies on Abel v. United States · Commissioner v. Gordon · McWilliams v. Commissioner · Hartford Fire Insurance v. Roberto · American Bantam Car 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““neither the language itself nor the legislative history suggests that all the stages of the indirect route from taxpayer back to taxpayer’s corporation or family member had to be under a binding commitment. If [the mortgagee] had not sold to U.L.C., none of this would be at issue. But it did in fact sell and U.L.C. is owned by the taxpayers.... The mechanics of the transaction should not divert attention from the fact that taxpayers have not sustained any genuine loss in the asset.””
4 later decisions quote this exact passage · from the majority““The property was taken from [the taxpayer] by operation of law. He was without choice as to the time when the state would proceed against the property and, consequently, could not have selected the time for the realization of a taxable loss_ Neither is there the slightest indication of any prearrangement between the [taxpayer] and his corporation or anybody else. The property was purchased at a public sale where the bidding was spirited, and there is a strong presumption that it sold for not less than its fair value.””
2 later decisions 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.