Lewis v. Commissioner’s Empirical Analysis
176 F.2d 646 · 1949
Citation profile
63 federal appellate · 1 district ·
How this case has been cited
Cited by 106 later decisions (1 by the Supreme Court) — most recently March 2003 · most notably Commissioner v. Clark (1989), Pridemark, Inc. v. Commissioner of Internal Revenue (1965)
63 federal appellate · 1 district ·
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
Applies 26 U.S.C. § 112 · 26 U.S.C. § 115
Relies on Gregory v. Helvering · Hormel v. Helvering · Commissioner of Internal Revenue v. Bedford's Estate · Bazley v. Commissioner · Helvering v. Gregory
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 106 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(g) Definition of Reorganization.— * * * (1) The term “reorganization” means * * * (D) a transfer by a corporation of all or a part of its assets to another corporation -If immediately after the transfer the transferor or its shareholders or both are in control of the corporation to which the assets are transferred, * * *”
5 later decisions quote this exact passage“'the essence of [a statutory reorganization] is a continuance of the proprietary interests in the continuing enterprise under modified corporate form, the transaction being deemed insufficiently closed economically to justify a tax at the time, except in so far as the stockholder gets something in addition to stock or securities in the reorganized company.'”
3 later decisions quote this exact passage“The liquidation of the old company does not change matters because a statutory reorganization may encompass as one of its incidents the liquidation of one of the corporations a party to the reorganization.”
3 later decisions quote this exact passage
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.