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← 71 TC 54 - Koch v. Commissioner

Koch v. Commissioner’s Empirical Analysis

1978

Citation profile

31
cited by 31 later decisions
August 2016
most recently cited

4 federal appellate · 1 district ·

How this case has been cited

Cited by 31 later decisions — most recently August 2016 · most notably Southern Pacific Transp. Co. v. Commissioner (1980), Sullivan v. United States (1980)

4 federal appellate · 1 district ·

18019781980199020002010decided

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 Stern v. Board of Levee Commissioners · Commissioner of Internal Revenue v. P G Lake · United States v. E. I. du Pont de Nemours & Co. · McGee v. Ekberg · Lipsitz 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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “have reference to the nature or character of the property and not to its grade or quality.”
    2 later decisions quote this exact passage
  2. “[we must] ascertain whether the nature and character of the transferred rights in and to the respective properties are substantially alike. In making this comparison, consideration must be given to the respective interests in the physical properties, the nature of the title conveyed, the rights of the parties, the duration of the interests, and any other factor bearing on the nature or character of the properties as distinguished from their grade or quality. [Koch v. Commissioner, 71 T.C. 54, 65 (1978).]”
    1 later decision quote this exact passage
  3. “The main distinction between the two transactions is the duration of the interests — an overriding royalty interest continues until the mineral deposit is exhausted whereas a carved-out oil payment right terminates usually when a specified quantity of minerals has been produced or a stated amount of proceeds from the sale of minerals has been received.”
    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.