254 F. Supp. 35 - Somers v. Gardner’s Empirical Analysis

Citation profile

2 federal appellate · 1 district ·

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

1. ““Additionally, there is substantial authority for the general principle that the Secretary can allocate funds in fact paid out by a corporation in order to properly reflect the value of services rendered by employees and to prevent fraudulent arrangements which are tantamount to ‘shifting wages.’ Dondero v. Celebrezze, 312 F.2d 677 [2 Cir., 1963]; Newman v. Celebrezze, 310 F.2d 780 [2 Cir. 1962] ; Poss v. Ribicoff, 289 F.2d 10 [2 Cir. 1961]; Stark v. Flemming, 283 F.2d 410 [9 Cir. 1960]; Flemming v. Lindgren, 275 F.2d 596 [9 Cir., 1960]; Brannon v. Ribicoff, 200 F.Supp. 697 [D.Mont.1961].” Somers v. Gardner, cit. supra, 254 F.Supp. pp. 36 and 37.”

   2 later decisions quote this exact passage
   e.g. Colussi v. Richardson · Johnson v. Chater

2. “Admittedly, where dividends are in fact received by the sole stockholder who has performed services for his corporation, there may be authority for permitting the Secretary to reclassify the de facto dividends as salary to reflect appropriate compensation for such services. 16 * * * * * * 17 Thus the absence of a reclassification would permit the receipt in fact of income in return for services which income would not be applied against social security benefits.”

   1 later decision quote this exact passage
   e.g. Ludeking v. Finch

3. “However, no case has been cited nor found by this Court which authorizes the Secretary to”

   1 later decision quote this exact passage
   e.g. Johnson v. Chater