Helvering v. Sprouse’s Empirical Analysis

Citation profile

21 federal appellate · 3 district · 3 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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““§ 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.”

   2 later decisions quote this exact passage · from the majority
   e.g. Pizitz v. Patterson · Chamberlin v. Commissioner of Internal Revenue (Two Cases). Toner v. Commissioner of Internal Revenue. Carl v. Commissioner of Internal Revenue. Schrock v. Commissioner of Internal Revenue. Pierce v. Commissioner of Internal Revenue

2. “brought about no change whatever in his interest in the corporation. Both before and after the event he owned exactly the same interest in the net value of the corporation as before. At both times he owned it all and retained all the incidents of ownership he had enjoyed before.”

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

3. “the distribution of the dividend in nowise disturbed the relationship previously existing amongst all the stockholders, or that previously existing between the * * * [taxpayer] and the corporation.”

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