Roe v. Commissioner’s Empirical Analysis

Citation profile

2 federal appellate ·

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

1. ““(l) Effect on earnings and profits of gain or loss and of receipt of tax-free distributions. * * * * * * Where a corporation receives (after February 28, 1913) a distribution from a second corporation which (under the law applicable to the year in which the distribution was made) was not a taxable dividend to the shareholders of the second corporation, the amount of such distribution shall not increase the earnings and profits of the first corporation in the following cases: “(1) No such increase shall be made in respect of the part of such distribution which (under such law) is directly applied in reduction of the basis of the stock in respect of which the distribution was made. “(2) No such increase shall be made if (under such law) the, distribution causes the basis of the stock in respect of which the distribution was made to be allocated between such stock and the property received.””

   3 later decisions quote this exact passage
   e.g. Roe v. Commissioner · Roe v. Commissioner of Internal Revenue

2. “(2) No such increase shall be made if (under such law) the distribution causes the basis of the stock in respect of which the distribution was made to be allocated between such stock and the property received.”

   1 later decision quote this exact passage
   e.g. Roe v. Commissioner

3. “to the stockholders. Thereafter, from time to time, Cummer Lime made payments to the stockholders on these”

   1 later decision quote this exact passage
   e.g. Roe v. Commissioner