Moline Properties, Inc. v. Commissioner’s Empirical Analysis
319 U.S. 436 · 1943
Citation profile
653 federal appellate · 63 district · 89 state decisions
How this case has been cited
Cited by 1,841 later decisions (10 by the Supreme Court) — most recently March 2021 · most notably Interstate Transit Lines v. Commissioner (1943), National Carbide Corporation v. Commissioner of Internal Revenue (1949)
653 federal appellate · 63 district · 89 state decisions — followed in 21 states
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. Moline Properties, Inc. (from Fifth Circuit Court of Appeals)
Relationships
Relies on New Colonial Ice Co. v. Helvering · Gregory v. Helvering · Deputy v. du Pont · Higgins v. Smith
Cited together with National Carbide Corporation v. Commissioner of Internal Revenue · Higgins v. Smith · Gregory v. Helvering · Burnet v. Commonwealth Improvement Co. · New Colonial Ice Co. v. Helvering
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 1,841 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The doctrine of corporate entity fills a useful purpose in business life. Whether the purpose be to gain an advantage under the law of the state of incorporation or to avoid or to comply with the demands of creditors or to serve the creator’s personal or undisclosed convenience, so long as that purpose is the equivalent of business activity or is followed by the carrying on of business by the corporation, the corporation remains a separate taxable entity.”
46 later decisions quote this exact passage · from the majority“the corporate form may be disregarded where it is a sham or unreal.”
14 later decisions quote this exact passage · from the majority“There was no actual contract of agency, nor the usual incidents of an agency relationship.”
4 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.