Lawrence v. MacFarland’s Empirical Analysis
1962
Citation profile
4 state decisions
Relationships
Relies on Tax Commissioner v. Putnam · First Nat. Bank of Memphis v. McCanless · Commissioner of Corporations & Taxation v. Filoon · 11 Smith & H. 672 - Evans v. McCabe, Comr. · Fidelity-Bankers Trust Co. v. McCanless
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.
“It seems to us that when the Legislature enacted § 67-2609 [now T.C.A. § 67-2-104(k),] above quoted, and provided that no distribution of capital should be taxed they tried to amplify that by liquidation or otherwise, but when they put the exception [in,] the purpose was [to] include everything else above the original capital of the corporation as earned surplus and make it taxable. In our view of the matter that can be the only proper interpretation to come to upon a careful study of this Act.”
1 later decision quote this exact passage · from the majoritye.g. Dobson v. Huddleston“This case, for the first time, presents the question of whether or not the amounts received by owners of shares ... from regulated investment companies, which amounts to pro rata distributions of gains realized by said concern upon disposition of securities held in its portfolio (under the Federal Income regulations, commonly called capital gains) are subject to income taxation under the Hall Income Tax.”
1 later decision quote this exact passage · from the majoritye.g. Dobson v. Huddleston“Whatever they were called by the Trust does not concern the taxing authorities. The only matter as far as the statute is concerned “is that complainants received certain payments on account of their ownership of shares in a business concern, and that complainants’ right to such payments did not represent to complainants a return of the capital originally invested by complainants in such shares.””
1 later decision quote this exact passage · from the majoritye.g. Dobson v. Huddleston
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.