Kerr v. Commissioner’s Empirical Analysis
1964
Citation profile
20 federal appellate · 1 district ·
How this case has been cited
Cited by 39 later decisions (1 by the Supreme Court) — most recently October 1987 · most notably United States v. Davis (1970), Glens Falls Insurance v. Newton Lumber & Mfg. Co. (1967)
20 federal appellate · 1 district ·
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 Southern Pac Co v. Lowe · Bowers v. Kerbaugh-Empire Co. · Commissioner of Internal Revenue v. Bedford's Estate · Massengale v. United States · Murray v. United States
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) Redemptions not equivalent to dividends. — Subsection (a) shall apply if the redemption is not essentially equivalent to a dividend.”
4 later decisions quote this exact passage · from the majority““The words ‘not essentially equivalent to a dividend’ are words of art. They are not further defined by Congress. However, in enacting § 302(b) (1), Congress intended that the test for determining whether a redemption was ‘essentially equivalent to a dividend’ should be the same as the test utilized in interpreting and applying the same words in § 115(g) (1) of the 1939 Code. S.Rep.No.1622, 83d Cong., 2d Sess., p. 234 (3 U.S.C.Cong. & Admin. News (1954) 4621, 4870).””
2 later decisions quote this exact passage · from the majority“a mixed question of law and fact, if not purely a conclusion of law.”
2 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.