Applegate v. Commissioner’s Empirical Analysis
1990
Citation profile
2 federal appellate ·
Relationships
Relies on Service Bolt & Nut Co. v. Commissioner · Service Bolt & Nut Co. Profit Sharing Trust v. Commissioner · Clyde G. Tatum and Veta Rae Tatum v. Commissioner of Internal Revenue · Ben F. Parmer and Mildred Helen Parmer v. Commissioner of Internal Revenue · Tatum 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The committee amendments also provide that bonds in registered form which the taxpayer establishes will not be readily tradeable [sic] in an established securities market are not to be treated as payments received in the year of sale, since because of their lack of ready marketability they do not possess the characteristics which would render them essentially similar to cash. [ S. Rept. 91-552 at 516 .]”
1 later decision quote this exact passage“Debentures, however, in most cases can be readily traded on the market and therefore are a close approximation of cash. Thus, the problem of the seller not having the cash with which to pay the tax due would not appear to be present where he receives debentures or other readily marketable securities. [S. Rept. 91-552 (1969), 1969- 3 C.B. 423 , 515.]”
1 later decision 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.