Bazley v. Commissioner’s Empirical Analysis
331 U.S. 737 · 1947
Citation profile
165 federal appellate · 15 district · 10 state decisions
How this case has been cited
Cited by 347 later decisions (1 by the Supreme Court) — most recently March 2015 · most notably Benjamin D. And Madeline Prentice Gilbert v. Commissioner of Internal Revenue (1957), Eli D. Goodstein v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Eli D. Goodstein (1959)
165 federal appellate · 15 district · 10 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
reviewedBazley v. Commissioner of Internal Revenue (from Third Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 112
Relies on Gregory v. Helvering · Dobson v. Commissioner · Pinellas Ice & Cold Storage Co. v. Commissioner · Le Tulle v. Scofield · Commissioner of Internal Revenue v. Bedford's Estate
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 347 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a formal distribution, directly or through exchange of securities, represents merely a new form of the previous participation in an enterprise involving no change of substance in the rights and relations of interested parties one to another or to the corporate assets.”
7 later decisions quote this exact passage · from the majority“(I)n the case of a corporation which has undistributed earnings, the creation of new corporate obligations which are transferred to stockholders in relation to their former holdings, so as to produce, for all practical purposes, the same result as a distribution of cash earnings of equivalent value, cannot obtain tax immunity because cast in the form of a recapitalization-reorganization.”
3 later decisions quote this exact passage · from the majority““While § 112(g) informs us that ‘reorganization’ means, among other things, ‘a recapitalization,’ it does not inform us what ‘recapitalization’ means. * * * Congress has never defined it and the Treasury Regulations shed only limited light.””
3 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.