Groman v. Commissioner’s Empirical Analysis
302 U.S. 82 · 1937
Citation profile
92 federal appellate · 6 district · 12 state decisions
How this case has been cited
Cited by 186 later decisions (10 by the Supreme Court) — most recently August 2025 · most notably Burgess v. United States (2008), Helvering v. Bashford (1938)
92 federal appellate · 6 district · 12 state decisions
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
reviewedCommissioner of Internal Revenue v. Groman (from Seventh Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 112
Relies on Pinellas Ice & Cold Storage Co. v. Commissioner · Helvering v. Minnesota Tea Co. · John A. Nelson Co. v. Helvering · Helvering v. Watts
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 186 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But to do so would be to ignore the purpose of the reorganization sections of the statute, which, as we have said, is that where, pursuant to a plan, the interest of the stockholders of a corporation continues to be definitely represented in substantial measure in a new or different one, then to the extent, but only to the extent, of that continuity of interest, the exchange is to be treated as one not giving rise to present gain or loss.” Groman v. Commissioner, 302 U.S. 82 , 89, 58 S.Ct. 108 , 112, 82 L.Ed. 63 .”
8 later decisions quote this exact passage · from the majority““SEC. 368. Definitions Relating to Corporate Reorganizations. (a) Reorganization.-— (1) In general. — For purposes of parts I and II and this part, the term ‘reorganization’ means— **■*•***' (B) the acquisition by one corporation, in exchange solely for all or a part of its voting stock, of stock of another corporation if, immediately after the acquisition, the acquiring corporation has control of such other corporation (whether or not such acquiring corporation had control immediately before the acquisition), ***••»* ■->:• (b) Party to a reorganization.— For purposes of this part, the term ‘a party to a reorganization’ includes— (1) a corporation resulting from a reorganization, and (2) both corporations, in the case of a reorganization resulting from the acquisition by one corporation of stock or properties of another.””
1 later decision quote this exact passage · from the majority““In general. — No gain or loss shall be recognized if stock or securities in a corporation a party to a reorganization are, in pursuance of the plan of reorganization, exchanged solely for stock or securities in such corporation or in another corporation a party to the reorganization.””
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.