Heman v. Commissioner’s Empirical Analysis
1959
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 54 later decisions — most recently August 2005 · most notably Heman v. Commissioner (1960), Stevens Bros. Foundation, Inc. v. Commissioner (1962)
9 federal appellate ·
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.
Relationships
Relies on Reserve Life Insurance v. Bankers Life & Casualty Co. · Massengale v. United States · Murray v. United States · Wall v. United States · Flanagan 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 54 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Among these criteria are: The presence or absence of a bona fide corporate business purpose; whether the action was initiated by the corporation or by the shareholders; did the corporation adopt any plan or policy of contraction, or did the transaction result in a contraction of the corporation’s business; did the corporation continue to operate at a profit; whether the transaction resulted in any substantial change in the proportionate ownership of stock held by the shareholders; what were the amounts, frequency, and significance of dividends paid in the past; was there a sufficient accumulation of earned surplus to cover the distribution, or was it partly from capital.” United States v. Carey, supra, 289 F.2d at 537 , quoting Heman v. Commissioner of Internal Revenue, 32 T.C. 479 (1959), aff’d, 283 F.2d 227 (8th Cir. 1960) (citations omitted).”
2 later decisions quote this exact passage“In the absence of evidence showing reliance on the advice of competent counsel, mere mistaken belief that no return was required under the statute because of lack of income does not constitute reasonable cause for noncompliance”
1 later decision quote this exact passage
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.