Patrick v. Commissioner’s Empirical Analysis
799 F.3d 885 · 2015
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 1221 · 26 U.S.C. § 1222
Relies on Vermont Agency of Natural Resources v. United States Ex Rel. Stevens · Kaiser Aetna v. United States · Commissioner v. Gillette Motor Transport, Inc. · Minnesota Mining & Manufacturing Co. v. Pribyl · Riley v. St. Luke's Episcopal Hospital
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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]reating a relator's reward as a capital gain would contravene the long-recognized rule that a 'capital gain' generally involves a 'realization of appreciation in value accrued over a substantial period of time' of an initial investment of capital.”
1 later decision quote this exact passage · from the majority“[t]he attorney's interest in future compensation for legal work, and [the relator's] interest in a future award for his investigative work, both constitute an interest in future payment for services”
1 later decision quote this exact passage · from the majority“Id. Thus, Plaintiffs have not demonstrated that they possessed a capital asset, and therefore their share from the qui tam suit cannot constitute a”
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.