Atlantic Co. v. Commissioner’s Empirical Analysis
129 F.2d 87 · 1942
Citation profile
6
cited by 6 later decisions
February 1945
most recently cited
4 federal appellate ·
Relationships
Relies on Helvering v. Northwest Steel Rolling Mills, Inc. · Mills v. Commissioner · Florence Cotton Mills 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In the case of a corporation the following credits shall be allowed to the extent provided in the various sections imposing tax- is * * * * “(c) Contracts Restricting Payment ol Dividends. # * # * * “(2) Disposition of profits of taxable year. An amount equal to the portion of the earnings and profits of the taxable year which is required (by a provision of a written contract executed by the corporation prior to May 1, 1936, which provision expressly deals with the disposition of earnings and profits of the taxable year) to be paid within the taxable year in discharge of a debt, or to be irrevocably set aside within the taxable year for the discharge of a debt; to the extent that such amount has been so paid or set aside. For the purposes of this paragraph, a requirement to pay or set aside an amount equal to a percentage of earnings and profits shall bo considered a requirement to pay or set aside such percentage of earnings and profits. As used in this paragraph, the word ‘debt’ does not include a debt incurred after April 30, 1936.” Revenue Act of 1930, 26 U.S.C.A. Int.Rev.Acts, page 836.”
1 later decision quote this exact passage · from the majority
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.