Thatcher v. Commissioner’s Empirical Analysis
1973
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 7 later decisions — most recently November 1997
3 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
Relies on Moses Lake Homes, Inc. v. Grant County · Jones v. United States · Mueller v. Commissioner · Jergens v. Commissioner · Bongiovanni 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * Nothing in sections 351 or 357 requires treatment of only one side of the receivable-payable 'sale' as a recognizing transaction. The statutory purpose is far better served if payables paid by the transferee in the taxable year of transfer are treated as deductible to the transferor to the extent the off-setting receivables are treated as received by him. Since payment of a deductible liability by a cash-method taxpayer gives rise to a deduction, the same deduction should be allowed on payment when section 357(c) treats the liability as assumed in exchange for receivables.”
1 later decision quote this exact passage“* * * if the sum of the amount of the liabilities assumed, plus the amount of the liabilities to which the property is subject, exceeds the total of the adjusted basis of the property transferred pursuant to such exchange, then such excess shall be considered as a gain from the sale or exchange of a capital asset or of property which is not a capital asset, as the case may be.”
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.