Nickell v. Commissioner’s Empirical Analysis
1987
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 8 later decisions — most recently June 2006
7 federal appellate ·
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. § 162 · 26 U.S.C. § 212 · 26 U.S.C. § 263 (Interest Equalization Tax Act)
Relies on Cox v. State of Louisiana · Dobson v. Commissioner · Bingham's Trust v. Commissioner of Internal Revenue · Kornhauser v. United States · Woodward 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[u]niformity among the circuits is especially important in tax cases to ensure equal and certain administration of the tax system,”
2 later decisions quote this exact passage · from the majority“The policy behind [ Treas. Reg. § 1.212 -l(k) ] is that expenses incurred in acquiring income-producing property — such .as brokerage fees incurred in the process of acquiring stocks — are part of the cost of the property, and are therefore treated as non-deductible capital expenditures. These expenditures are added to the basis of the capital asset in connection with which they are incurred, and are taken into account for tax purposes either through depreciation of the asset or through reduction of the capital gain (or augmentation of the loss) when the asset is sold.”
1 later decision quote this exact passage · from the majoritye.g. Dye v. United States“origin of taxpayers' claims was an attempt to collect income precisely to the extent that stock dividends and interest were recoverable in their suit.”
1 later decision quote this exact passage · from the dissent
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.