Keefe v. Cote’s Empirical Analysis
213 F.2d 651 · 1954
Citation profile
46 federal appellate · 3 district ·
How this case has been cited
Cited by 74 later decisions — most recently July 1978 · most notably Ferro v. Commissioner (1957), United States v. Fewell (1958)
46 federal appellate · 3 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. § 115 · 26 U.S.C. § 275
Relies on Commissioner of Internal Revenue v. Bedford's Estate · Murray v. United States · Wall v. United States · Flanagan v. Helvering · Boyle 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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Redemption of stock. * * * If a corporation cancels or redeems its stock (whether or not such stock was issued as a stock dividend) at such time and in such manner as to make the distribution and cancellation or redemption in whole or in part essentially equivalent to the distribution of a taxable dividend, the amount so distributed in redemption or cancellation of the stock, to the extent that it represents a distribution of earnings or profits accumulated after February 28, 1913, shall be treated as a taxable dividend.””
1 later decision quote this exact passage · from the majority““The question whether a distribution in connection with a cancellation or redemption of stock is essentially equivalent to the distribution of a taxable dividend depends upon the circumstances of each case.” Section 39.-H5(g)-1.(2)”
1 later decision quote this exact passage · from the majority“whenever the practical result of the transaction is to distribute accumulated earnings essentially pro rata among the shareholders while leaving the ownership of the corporation basically the same.”
1 later decision 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.