Phipps v. Commissioner’s Empirical Analysis
127 F.2d 214 · 1942
Citation profile
12 federal appellate · 1 district · 3 state decisions
How this case has been cited
Cited by 35 later decisions — most recently October 2000 · most notably Estate of Bright v. United States (1981), Shepherd v. Commissioner (2000)
12 federal appellate · 1 district · 3 state decisions
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
Relies on Alamo Nat. Bank v. Commissioner of Internal Revenue · Helvering v. Safe Deposit & Trust Co. · Helvering v. Maytag · Gamble v. Commissioner · Robinson 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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The reasoning on which this theory of valuation is based is that a large block of stock cannot ordinarily be marketed and turned into cash as readily as a few shares; also, that where there is only a limited market for a stock, offering a large block of the stock depresses the market and lowers the price that can be obtained for the stock. The conclusion that flows from this premise is that evidence of sales of small blocks of stock is not a cri terion of the value of a large block of ■ the same stock. “The ultimate place of the ‘blockage’ theory in the field of valuation has not yet been finally determined. The most that the courts have said is that it is a factor to be considered along with all others in determining value in computing gift taxes under the statute.” Authorities cited.”
1 later decision quote this exact passage · from the majoritye.g. Calvert v. Kattar
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.