Noell v. Commissioner’s Empirical Analysis
1976
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 25 later decisions — most recently November 2015 · most notably Sealy Power, Ltd. v. Commissioner (1995), Illinois Cereal Mills, Inc. v. Commissioner (1986)
6 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 Gersten v. Commissioner · O'Malley v. Ames · Colony, Inc. v. Commissioner · Colony, Inc. v. Commissioner · Willow Terrace Development Co. v. Commissioner of Internal Revenue
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“placed in a condition or state of readiness and availability for a specifically assigned function, whether in a trade or business, in the production of income, in a tax-exempt activity, or in a personal activity.”
3 later decisions quote this exact passage“clearly only a stage in the construction”
2 later decisions quote this exact passage“The critical question is whether petitioner intended to hold the facilities to realize a return on his capital from business operations, to recover his capital from a future sale, or some combination of the two; or whether, on the other hand, he so encumbered his property with rights running to the property owners (regardless of who retained nominal title) that he in substance disposed of these facilities, intending to recover his capital, and derive a return of his investment through the sale of the lots. 10 * * *”
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.