Bell v. Commissioner’s Empirical Analysis
1981
Citation profile
5
cited by 5 later decisions
March 1992
most recently cited
2 federal appellate ·
Relationships
Relies on Deputy v. du Pont · First National Bank v. Dickinson · Autenreith v. Commissioner of Internal Revenue · Autenreith v. Commissioner · Kohler v. Humphrey
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is clear that Mr. Bell did not forbear the collection of any ascertainable amount owed to him by petitioner pursuant to the sale, but accepted petitioner’s tenuous annuity obligation as full payment for the stock. Under these circumstances, we are convinced that petitioner’s annuity obligation is too indefinite to constitute an indebtedness within the meaning of section 163. See Dix v. Commissioner, 392 F.2d [313] at 318 [4th Cir.]. In the instant case, the full amount of each annuity payment represents a capital expenditure, and accordingly, petitioner is not entitled to any interest expense deduction therefor. [Bell v. Commissioner, supra, 76 T.C. at 238 (footnote omitted).]”
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.