Floyd v. Scofield’s Empirical Analysis
193 F.2d 594 · 1952
Citation profile
32 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 55 later decisions — most recently September 2019 · most notably Fisher v. Commissioner of Internal Revenue (1954), Williamson v. United States (1961)
32 federal appellate · 2 district · 1 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
Applies 26 U.S.C. § 311
Relies on Helvering v. Horst · Commissioner of Internal Revenue v. Court Holding Co · Commissioner v. First State Bank · Austin 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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The question here, as in Helver-ing v. Horst, 311 U.S. 112 , 61 S.Ct. 144 , 146, 85 L.Ed. 75 , is whether one who is presently entitled to receive income, and who is taxable only on receipt of payment, can escape taxation by giving away his right thereto in advance of actual payment. * * * “To hold that the corporation is not liable in these circumstances would enable it to escape taxation by the simple device of dissolving prior to the actual collection by it of monies fully earned by and payable to the corporation before liquidation. -» * * “The method of accounting employed by the corporation with respect to this transaction does not clearly reflect the corporate income. The Commissioner was well within his authority under Sec. 311, Int. Rev.Code, 26 U.S.C.A. § 311 , in reappraising the situation and requiring a computation by a method which clearly and accurately reflects the income in question.””
6 later decisions 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.