Helvering v. Southwest Consolidated Corp.’s Empirical Analysis
315 U.S. 194 · 1942
Citation profile
199 federal appellate · 20 district · 29 state decisions
How this case has been cited
Cited by 446 later decisions (15 by the Supreme Court) — most recently February 2018 · most notably Commissioner of Internal Revenue v. National Alfalfa Dehydrating and Milling Company (1974), Claridge Apartments Co. v. Commissioner (1944)
199 federal appellate · 20 district · 29 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 v. Southwest Consol. Corp. (from Fifth Circuit Court of Appeals)
Relationships
Relies on Helvering v. Alabama Asphaltic Limestone Co. · Helvering v. Minnesota Tea Co. · Miles v. Safe Deposit & Trust Co. · United States v. Hendler
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 446 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Congress has provided that the assets of the transferor corporation must be acquired in exchange 'solely' for 'voting stock' of the transferee. 'Solely' leaves no leeway. Voting stock plus some other consideration does not meet the statutory requirement.”
15 later decisions quote this exact passage · from the majority“reshuffling of a capital structure within the framework of an existing corporation,”
12 later decisions quote this exact passage · from the majority“(1) The term “reorganization” means . . (B) the acquisition by one corporation in exchange solely for all or a part of its voting stock: of at least 80 per centum of the voting stock and at least 80 per centum of the total number of shares of all other classes of stock of another corporation; or of substantially all the properties of another corporation.”
6 later decisions 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.