Kolom v. Comm'r’s Empirical Analysis
1978
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 48 later decisions (1 by the Supreme Court) — most recently June 2003 · most notably Graff v. Commissioner (1980), McDonald v. Commissioner (1985)
8 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 15 U.S.C. § 781 · 15 U.S.C. § 78P (§ 16 of the Securities Exchange Act of 1934)
Relies on United States v. Cartwright · Commissioner v. LoBue · Commissioner v. Smith · Arrowsmith v. Commissioner · Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. 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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"(h) Nonlapse restriction. For purposes of section 83 and the regulations thereunder, a restriction which by its terms will never lapse (also referred to as a ‘nonlapse restriction’) is a permanent limitation on the transferability of property— "(1) Which will require the transferee of the property to sell, or offer to sell, such property at a price determined under a formula, and “(2) Which will continue to apply to and be enforced against the transferee or any subsequent holder (other than the transferor). "... Limitations imposed by registration requirements of State or Federal security laws or similar laws imposed with respect to sales or other dispositions of stock or securities are not nonlapse restrictions. An obligation to resell or to offer to sell property transferred in connection with the performance of services to a specific person or persons at its fair market value at the time of such sale is not a nonlapse restriction____"”
4 later decisions quote this exact passage“(b) RESTRICTIONS ON EXAMINATION OF TAXPAYER — No taxpayer shall be subjected to unnecessary examination or investigations, and only one inspection of a taxpayer’s books of account shall be made for each taxable year unless the taxpayer requests otherwise or unless the Secretary or his delegate, after investigation, notifies the taxpayer in writing that an additional inspection is necessary.”
2 later decisions quote this exact passage“§ 83. Property transferred in connection with performance of services”
2 later decisions 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.