Commissioner v. Simmons’s Empirical Analysis
646 F.3d 6 · 2011
Citation profile
10 federal appellate ·
Relationships
Applies 26 U.S.C. § 170 · 26 U.S.C. § 501
Relies on Bond v. Commissioner · Taylor v. Commissioner · Hilborn v. Commissioner · Sitka Sound Seafoods, Inc. v. National Labor Relations Board · Spirit of the Sage Council v. Norton
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“obtain [and retain] a qualified appraisal for the property contributed”
3 later decisions quote this exact passage · from the majority“If no substantial record of market-place sales is available to use as a meaningful or valid comparison ... the fair market value of a perpetual conservation restriction is equal to the difference between the fair market value of the property it encumbers before the granting of the restriction and the fair market value of the encumbered property after the granting of the restriction.”
2 later decisions quote this exact passage · from the majority“[a]ny donee might fail to enforce a conservation easement, with or without a clause stating it may consent to a change or abandon its rights, and a tax-exempt organization would do so at its peril.”
2 later decisions quote this exact passage · from the majoritye.g. Kaufman v. Shulman · Belk v. Comm'r
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.