Helvering v. Griffiths’s Empirical Analysis

Citation profile

137 federal appellate · 3 district · 40 state decisions

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

1. “Nothing in the history or attitude of this Court should give rise to legislative embarrassment if in the performance of its duty a legislative body feels impelled to enact laws which may require the Court to reexamine its previous judgments or doctrine. The Court differs, however, from other branches of the Government in its ability to extricate itself from error. It can reconsider a matter only when it is again properly brought before it in a case or controversy; and if the case requires, as a tax case does, a statutory basis for a case, the new case must have sufficient statutory support.”

   3 later decisions quote this exact passage · from the majority
   e.g. In Re A.V.B.I., Inc. · Prudential Ins. Co. v. Barnett

2. ““§ 115. Distributions by corporations. ****** “(f) Stock Dividends— "(1) General rule. A distribution made by a corporation to its shareholders in its stock or in rights to acquire its stock shall not be treated as a dividend to the extent that it does not constitute income to the shareholder within the meaning of the Sixteenth Amendment to the Constitution. * * * ” 26 U.S.C. 1952 ed., Sec. 115.”

   3 later decisions quote this exact passage · from the majority
   e.g. Pizitz v. Patterson · Messer v. Commissioner

3. “It would be a pity if taxpayers could not rely on this concurrent assurance from all three branches of the Government.”

   2 later decisions quote this exact passage · from the majority
   e.g. Chattanooga Auto. Club v. Commissioner · Stockstrom v. Commissioner of Internal Revenue