Sidney v. Commissioner’s Empirical Analysis
1958
Citation profile
6 federal appellate ·
How this case has been cited
Cited by 30 later decisions — most recently June 1994 · most notably Rose v. Commissioner (1970), Sidney v. Commissioner (1960)
6 federal appellate ·
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
Relies on Raymond G. Burge and Kathleen E. Burge v. Commissioner of Internal Revenue · Arthur Glickman Herman Glickman and Ruth Glickman and Aaron Glickmand and Freda Glickman v. Commissioner of Internal Revenue · Sorin v. Commissioner · Payne v. Commissioner · August v. Commissioner
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Petitioners make a further argument to the effect that even though the corporations are deemed collapsible corporations within the meaning of section 117 (m), only a portion of the cash distributions made by them is taxable under that section because such distributions (to the extent that they were not ordinary dividends paid from current earnings) were in amounts less than the excess of the mortgage proceeds over the “total cost of construction.” The fallacy in this argument lies in the fact that petitioners have included in the “total cost of construction” the cost of the land. On the authority of Elizabeth M. August, 30 T.C. 969 , this argument is rejected.”
1 later decision 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.