Coady v. Commissioner’s Empirical Analysis
1960
Citation profile
18 federal appellate ·
How this case has been cited
Cited by 45 later decisions — most recently August 1992 · most notably Evans v. Commissioner (1967), Idol v. Commissioner (1963)
18 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 Gregory v. Helvering · Commissioner of Internal Revenue v. South Texas Lumber Co · Brewster v. Gage · Bazley v. Commissioner · Helvering v. Gregory
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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“SEC. 1.355-1. Distribution of stock and securities of controlled corporation. — (a) Application of section. Section 355 provides for the separation, without recognition of gain or loss to the shareholders and security holders, of two or more existing businesses formerly operated, directly or indirectly, by a single corporation. It applies only to the separation of existing businesses which have been in active operation for at least five years, and which, in general, have been owned for at least five years by the corporation making the distribution of stock or of stock and securities. Section 355 does not apply to the division of a single business * * *”
1 later decision quote this exact passage · from the dissent“a specific existing group of activities being carried on for the purpose of earning income or profit from only such group of activities, and the activities included in such group must include every operation which forms a part of, or a step in, the process of earning income or profit from such group. Such group of activities ordinarily must include the collection of income and the payment of expenses. * * *”
1 later decision quote this exact passage · from the dissent“(B) such trade or business has been actively conducted throughout the 5-year period ending on the date of the distribution.”
1 later decision quote this exact passage · from the dissent
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.