Patterson v. Commissioner’s Empirical Analysis
1987
Citation profile
12 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 48 later decisions (1 by the Supreme Court) — most recently June 2017 · most notably Newark Morning Ledger Co. v. United States (1993), North American Rayon Corp. v. Commissioner (1993)
12 federal appellate · 1 district · 4 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 26 U.S.C. § 7482
Relies on Welch v. Helvering · Commissioner of Internal Revenue v. Duberstein D Stanton · Commissioner of Internal Revenue v. Court Holding Co · Roberts v. Florida · Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennan
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.
“As consideration for part of the purchase price * * * Patterson agrees, simultaneously with the execution of this Agreement, to enter into a Covenant Not to Compete in the form attached hereto”
1 later decision quote this exact passage · from the majoritye.g. Becker v. Comm'r“amounts received by a seller for a non-competition covenant are considered to be given as compensation for lost earnings and, as such, are taxable as ordinaiy income.”
1 later decision quote this exact passage · from the majority“[t]he Danielson rule can only be meaningfully applied in those cases where a specific amount has been mutually allocated to the covenant as expressed in the contract.”
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.