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← 141 F.2d 452 - Beretta v. Commissioner

Beretta v. Commissioner’s Empirical Analysis

141 F.2d 452 · 1944

Citation profile

22
cited by 22 later decisions
September 1988
most recently cited

13 federal appellate · 1 district ·

How this case has been cited

Cited by 22 later decisions — most recently September 1988

13 federal appellate · 1 district ·

9019441950196019701980decided

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 Eisner v. Macomber · Kennemer v. Commissioner · Holmby Corp. v. Commissioner of Internal Revenue · Canal-Commercial Trust & Savings Bank v. Commissioner · Wilcox 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““A reduction in par value of capital stock upon a pro rata payment to each stockholder without an intent to wind up its affairs does not render such payment a distribution in partial liquidation, and in the absence of such intent and in the absence of the complete cancellation or redemption of a part of the stock by such payment the payment is taxable as income.” Beretta v. C. I. R., 141 F.2d 452 -455 (5 Cir.).”
    1 later decision quote this exact passage · from the majority
  2. “There must be a manifest intention to liquidate and a continuing purpose to terminate and dissolve the corporation. Its activities must be directed to that end.”
    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.