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← 744 F.3d 648 - Esgar Corp. v. Commissioner

Esgar Corp. v. Commissioner’s Empirical Analysis

744 F.3d 648 · 2014

Citation profile

21
cited by 21 later decisions
April 2020
most recently cited

8 federal appellate · 1 district ·

Relationships

Applies 26 U.S.C. § 1223 · 26 U.S.C. § 170 · 26 U.S.C. § 7482 · 26 U.S.C. § 7491

Relies on Anderson v. City of Bessemer City · Welch v. Helvering · Indopco, Inc. v. Commissioner · Olson v. United States · Dobson 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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “the [before value] take into account not only the current use of the property but also an objective assessment of how immediate or remote the likelihood is that the property, absent the restriction, would in fact be developed, as well as any effect- from zoning,, conservation, or historic preservation laws that already restrict the property’s potential highest and best use.”
    1 later decision quote this exact passage · from the majority
  2. “[T]he fair market value of a perpetual conservation restriction [in this case, a conservation easement] is equal to the difference between the fair market value of the property it encumbers before the granting of the restriction [the “before” value] and the fair market value of the encumbered property after the granting of the restriction [the “after” value].”
    1 later decision quote this exact passage · from the majority
  3. “It is the function of the Tax Court to draw appropriate inferences, and choose between conflicting inferences in finding the facts of a case. The Tax Court may draw these inferences from the whole record, including the Commissioner's evidence on a given fact and the taxpayer's lack thereof.”
    1 later decision 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.