Commissioner v. Cohen’s Empirical Analysis

Citation profile

8 federal appellate · 1 district · 2 state decisions

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

1. “* * * Under the law of Texas, a declaration of dividends creates a debt owed by the corporation in favor of each stockholder which cannot be rescinded. Although the declaration of this dividend provided that the sums thereunder were payable to the stockholders of record at such times and in such installments during the year as the directors saw fit, the liability of the company accrued as of the date of the declaration, which was prior to the taxpayer’s death. * * * -x- * -x- ipjjg stockholder receives the value of a dividend when it is declared, for if it is immediately paid he has his stock and his dividend, and if payment is deferred he has the value of his stock increased by the amount of the dividend upon it. * * * [Footnote omitted.] [Id. at 349.]”

   2 later decisions quote this exact passage · from the majority
   e.g. Kimberly-Clark Corp. v. Factory Mutual Insurance · McKelvy v. United States