Hirsch v. Commissioner’s Empirical Analysis

Citation profile

44 federal appellate · 2 district ·

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

1. “(1) In general. If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend, the amount so distributed in redemption or cancellation of the stock, to the extent that it represents a distribution of earnings or profits accumulated after February 28, 1913, shall be treated as a taxable dividend.””

   5 later decisions quote this exact passage · from the majority
   e.g. Earle v. Woodlaw · Lukens v. Commissioner

2. “A taxpayer should not be permitted to close his eyes to the obvious, and to carry accounts on his books as good when in fact they are worthless, and then deduct them in a year subsequent to the one in which he must be presumed to have ascertained their worthlessness.”

   2 later decisions quote this exact passage · from the majority
   e.g. James A. Messer Co. v. Commissioner · Rutter v. Comm'r

3. ““If the stockholder borrows money from the company, and subsequently the company cancels the debt, income accrues to the stockholder at the time when the character of the withdrawal changes from a loan to a distribution of profits.””

   1 later decision quote this exact passage · from the majority
   e.g. Earle v. Woodlaw