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← 242 F.2d 838 - Ferro v. Commissioner

Ferro v. Commissioner’s Empirical Analysis

1957

Citation profile

93
cited by 93 later decisions
September 1980
most recently cited

47 federal appellate · 3 district ·

How this case has been cited

Cited by 93 later decisions — most recently September 1980 · most notably Holsey v. Commissioner of Internal Revenue (1958), United States v. Fewell (1958)

47 federal appellate · 3 district ·

6501957196019701980decided

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

Relies on Old Colony Trust Co. v. Commissioner · Douglas v. Willcuts · Commissioner of Internal Revenue v. Scottish American Inv Co · Murray v. United States · United States v. Boston & Maine Railroad

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

  1. ““(g) 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 he treated as a taxable dividend.” 26 U.S.C. § 115 (g).”
    2 later decisions quote this exact passage · from the majority
  2. ““The declaration of a true dividend leaves the ownership and control of a corporation unaffected. Where a distribution of corporate assets likewise leaves proportionate interests unchanged, that circumstance has been termed ‘the most significant factor in finding dividend equivalence.’ ””
    2 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.