Freeland v. Commissioner’s Empirical Analysis
1980
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 48 later decisions — most recently June 2019 · most notably Ebben v. Commissioner (1986), Guest v. Commissioner (1981)
12 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 26 U.S.C. § 1211
Relies on Helvering v. Hallock · Crane v. Commissioner · Helvering v. Hammel · Izzi v. United States · 68 Cal. 2d 864 - Gerhard v. Stephens
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.
“We believe the holdings of Crane and subsequent cases decided in the light of Crane mandate the conclusion that relief from indebtedness, even though there is no personal liability, is sufficient to support a sale or exchange.”
3 later decisions quote this exact passage · from the majority“[T]here has been sufficient change in the judicial thinking on this subject, as evidenced by the cases decided since 1941, to cast considerable doubt on the validity of those decisions, and it would be wrong for us to ignore the more recent approaches to this issue simply to adhere to [stare decisis]. * * * [T]he validity of those cases has been sapped long before this, and the handwriting has been on the wall long before today. 74 T.C. at 982 (footnote and citation omitted)”
2 later decisions quote this exact passage · from the majority“Congress intended the words 'sale or exchange' to have a broad meaning, not to be limited to the standard transfer of property by one person to another in exchange for a stated consideration in money or money's worth.”
2 later decisions quote this exact passage · from the majority
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.