McDonald v. Commissioner’s Empirical Analysis
1985
Citation profile
29 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 58 later decisions — most recently October 2015 · most notably Estate of Wallace v. Commissioner (1992), Gantner v. Commissioner (1989)
29 federal appellate · 1 district · 1 state decisions
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. § 78P (§ 16 of the Securities Exchange Act of 1934) · 26 U.S.C. § 422 · 26 U.S.C. § 56 · 26 U.S.C. § 7805 · 26 U.S.C. § 83
Relies on International Brotherhood of Teamsters v. United States · Griggs v. Duke Power Co. · United States v. Correll · United States v. Cartwright · Washington Post Co. v. Rebozo
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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Joint Committee is a staff committee, and its 'Explanation[ ]' was issued after the fact. Hence it does not directly represent the views of the legislators or an explanation available to them when acting on the bill. The Joint Committee's views, however, are entitled to great respect.”
2 later decisions quote this exact passage · from the majority“[I]f the conditions of sections 421 and 422 are not met, then the employee exercising the unqualified option normally recognizes ordinary compensation income, and his employer a deduction, in the amount that the option price is exceeded by the stock’s then “fair market value ... determined without regard to any restriction other than a restriction which by its terms will never lapse." § 83(a)(1). On the other hand, if the conditions of sections 421 and 422 are met, no income to the employee (or deduction to the employer) is recognized respecting the exercise of the option; section 83(e)(1) provides that section 83 does not apply to the option exercise; and, if following the three-year period mandated by section 422(a), the stock is disposed of at a price greater than the option price, the resulting gain is taxed at the more favorable long-term capital gains rates.”
1 later decision quote this exact passage · from the majority“If, in connection with the performance of services, property is transferred to any person other than the person for whom such services are performed, the excess of— (1) the fair market value of such property (determined without regard to any restriction other than a restriction which by its terms will never lapse) at the first time the rights of the person having the beneficial interest in such property are transferable or are not subject to a substantial risk of forfeiture, whichever occurs earlier, over (2) the amount (if any) paid for such property, shall be included in the gross income of the person who performed such services in the first taxable year in which the rights of the person having the beneficial interest in such property are transferable or are not subject to a substantial risk of forfeiture, whichever is applicable.”
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.