William Liddon v. Commissioner of Internal Revenue, Maria Prothro Liddon v. Commissioner of Internal Revenue’s Empirical Analysis
1956
Citation profile
20 federal appellate · 1 district ·
How this case has been cited
Cited by 44 later decisions — most recently March 1991 · most notably J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn Davant (1966), South Texas Rice Warehouse Co. v. Commissioner (1965)
20 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 Helvering v. Alabama Asphaltic Limestone Co. · Commissioner of Internal Revenue v. Bedford's Estate · Lewis v. Commissioner · United States v. Arcade Co.
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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Moreover, since at the beginning of the series of transactions the petitioners held stock in the old corporation, and at the end they held stock in the new corporation, plus ‘money-to-boot,’ the court reasoned that, although there was not a direct exchange of stock in the old corporation for stock in the new, plus ‘other property or money,’ that was the net effect of what was done. Accordingly, the court concluded that the case was governed by sections 112(b) (3) and 112(c) of the 1939 Code.””
3 later decisions quote this exact passage · from the majority“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,”
3 later decisions quote this exact passage · from the majority“in control of the same going business as before, albeit in a new corporate shell, having in the meantime extracted a substantial portion of the accumulated earnings and profits of the business.”
3 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.