Midland Refining Co. v. Commissioner’s Empirical Analysis

Citation profile

3 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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “A careful examination of the stockholdings and the relationships existing between the various holders shows that substantially all of the slock is owned or controlled by the same individuals. It seems to follow, naturally, if a group of individuals owns or controls substantially all of the stock of both corporations, and if such ownership or control is by all exercised for one purpose, namely, the joint success of the corporations, that these individuals meet the requirements of the words “ the same interests.””

   4 later decisions quote this exact passage
   e.g. Wilshire Oil Co. v. Commissioner · Adolph Hirsch & Co. v. Commissioner

2. ““For the purpose of this section two or more domestic corporations shall be deemed to be affiliated (1) if one corporation owns directly or controls through closely affiliated interests or by a nominee or nominees substantially all the stock of the other or others, or (2) if substantially all the stock of two or more corporations is owned or controlled by the same interests.””

   2 later decisions quote this exact passage
   e.g. Howes Bros. Hide Co. v. Commissioner · North McAlester Coal Co. v. Commissioner