Wilson v. Commissioner’s Empirical Analysis

Citation profile

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

1. “are not defined, and that, in our opinion, the words were intended to include only what was in fact a distribution, leaving it for the courts to determine what was and what was not included within that term. Entirely aside from the decision that so much of the law as taxes a stock dividend as income is unconstitutional, the Supreme Court has pointed out that a stock dividend does not, in fact, distribute any property, and for that reason such a dividend does not, we believe, fall within the words”

   1 later decision quote this exact passage · from the majority
   e.g. Hedrick v. Commissioner

2. “used in the Act appears to have been deliberately chosen in the light of the language used by the court in Gibbons v. Mahon, supra , either to include or exclude a stock dividend, dependent upon whether or not such a dividend was a distribution. Nowhere in the Act are the words”

   1 later decision quote this exact passage · from the majority
   e.g. Hedrick v. Commissioner

3. “plainly intended that a stock dividend should be included within those words. It is our opinion that the Act had the twofold purpose mentioned above, and that the words”

   1 later decision quote this exact passage · from the majority
   e.g. Hedrick v. Commissioner