Edwards v. Douglas’s Empirical Analysis
269 U.S. 204 · 1925
Citation profile
60 federal appellate · 10 district · 38 state decisions
How this case has been cited
Cited by 187 later decisions (14 by the Supreme Court) — most recently September 2011 · most notably Willcuts v. Milton Dairy Co. (1927), Mason v. Routzahn (1927)
60 federal appellate · 10 district · 38 state decisions — followed in 11 states
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.
Appellate journey
reviewedthe decision below (from Second Circuit Court of Appeals)
Relationships
Relies on Lynch v. Hornby · LaBelle Iron Works v. United States · Penn Mut Life Ins Co v. Lederer · Peabody v. Eisner
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 187 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The surplus account represents the net assets of a corporation in excess of all liabilities including its capital stock. This surplus may be ‘paid-in surplus,’ where the stock is issued at a price above par; it may be ‘earned surplus,’ as where it was derived wholly from undistributed profits; or it may, among other things, represent the increase in valuation of land or other assets made upon a revaluation of the company’s fixed property.””
5 later decisions quote this exact passage · from the majority““Its general aim was clearly to make the dividend, in whatever year paid, bear the tax'rate of the year in which the profits of which it was a distribution had been earned, and for this purpose to treat as a unit the profits of the whole tax year. In providing measures for the attainment of that aim, it could be of no practical significance whether, at the time of the payment of the'dividend, these profits appeared in a surplus or undivided profits account (as the profits earned within parf of a year would, where a corporation closed its books monthly, quarterly, or semiannually) or whether they still rested as current earnings without formal determination or specific allocation.””
1 later decision quote this exact passage · from the majority““We think it was the purpose of the statute that any distribution made to shareholders should be conclusively presumed to have been made from the most recently accumulated undivided profits or surplus, and that it was intended that the corporation should not be permitted to determine to what year or period or to what fund it would allocate such distribution.””
1 later decision quote this exact passage
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.