Ferro v. Commissioner’s Empirical Analysis
1957
Citation profile
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 ·
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.
““(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““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.