Commissioner v. Rail Joint Co.’s Empirical Analysis
61 F.2d 751 · 1932
Citation profile
11 federal appellate · 1 state decisions
How this case has been cited
Cited by 24 later decisions (1 by the Supreme Court) — most recently April 2007
11 federal appellate · 1 state decisions
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. § 954
Relies on Burnet v. Sanford & Brooks Co. · Maryland Casualty Co. v. United States · United States v. Kirby Lumber Co. · Bowers v. Kerbaugh-Empire Co. · Charleston & W. C. Ry. Co. v. Burnet
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But it is not universally true that by discharging a liability for less than its face the debtor necessarily receives a taxable gain.”
2 later decisions quote this exact passage · from the majority“never received any increment to its assets, either at the time the bonds were delivered or at the time they were retired.... [T]he corporation received no asset which it did not possess prior to the opening and closing of the bond transaction, and it is impossible to see wherein it has realized any taxable income. In such circumstances the Kirby Case cannot be regarded as controlling.”
1 later decision quote this exact passage · from the majority“the purchase and retirement of the bonds in the two years in question resulted in decreasing the corporation's liabilities without a corresponding decrease in its assets, and the petitioner contends that the difference should be deemed income....”
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.