Hadley v. Commissioner’s Empirical Analysis

Citation profile

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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “amounts distributed in partial liquidation of a corporation shall be treated as in part or full payment in exchange for the stock. The gain or loss to the distributee resulting from such exchange shall be determined under section 111, but shall be recognized only to the extent provided in section 112. Despite the provisions of section 117 , the gain so recognized shall be considered as a short-term capital gain, except in the case of amounts distributed in complete liquidation.”

   1 later decision quote this exact passage
   e.g. Hathaway v. Commissioner

2. “(i) Definition of Partial Liquidation. - As used in this section the term 'amounts distributed in partial liquidation' means a distribution by a corporation in complete cancellation or redemption of a part of its stock, or one of a series of distributions in complete cancellation or redemption of all or a portion of its stock.”

   1 later decision quote this exact passage
   e.g. Buckley v. Commissioner

3. “The character of the transaction must be judged by what occurred when the petitioner surrendered his certificate in exchange for payment,”

   1 later decision quote this exact passage
   e.g. Hathaway v. Commissioner