Commissioner of Internal Revenue v. Bedford's Estate’s Empirical Analysis
325 U.S. 283 · 1945
Citation profile
201 federal appellate · 12 district · 5 state decisions
How this case has been cited
Cited by 378 later decisions (29 by the Supreme Court) — most recently September 2016 · most notably Bingham's Trust v. Commissioner of Internal Revenue (1945), United States v. F. & M. Schaefer Brewing Co. (1958)
201 federal appellate · 12 district · 5 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
reviewedBedford's Estate v. Commissioner (from Second Circuit Court of Appeals)
Relationships
Relies on Dobson v. Commissioner · Medo Photo Supply Corporation v. National Labor Relations Board · Commercial Molasses Corp. v. New York Tank Barge Corp. · Smith v. Shaughnessy
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 378 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“effect of the distribution of a dividend.”
4 later decisions quote this exact passage · from the majority“If a distribution made in pursuance of a plan of reorganization is within the provisions of paragraph (1) of this subsection but has the effect of the distribution of a taxable dividend, then there shall be taxed as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be taxed as a gain from the exchange of property.”
2 later decisions quote this exact passage · from the majority““As is true of other teasing questions of construction raised by technical provisions of Revenue Aets the matter is not wholly free from doubt. But these doubts would have to be stronger than they are to displace the informed views of the Tax Court.””
1 later decision 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.