Smith v. Commissioner’s Empirical Analysis
1936
Citation profile
3 federal appellate ·
How this case has been cited
Cited by 27 later decisions — most recently November 1983 · most notably James Armour, Inc. v. Commissioner (1964), Claude Neon Lights v. Commissioner (1937)
3 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 Pinellas Ice & Cold Storage Co. v. Commissioner · Helvering v. Minnesota Tea Co. · Arctic Ice Machine Co. v. Commissioner · St. Onge v. Commissioner · Gross v. Commissioner
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The respondent contends that the phrase “substantially all the properties” refers to the gross assets, rather than net, and that the 71 percent of gross assets transferred in this case was not “substantially all.” We think it unnecessary to decide whether the quoted phrase refers to the gross value of the assets or such value less liabilities. Whether the properties transferred constitute “substantially all” is a matter to be determined from the facts and circumstances in each case rather than by the application of any particular percentage. It might well be, as said by the respondent, that if a corporation having gross assets of $1,000,000 and liabilities of $900,000 transferred only the net assets of $100,000 the result would not come within the intent of Congress in its use of the words “substantially all.” Any number of further suppositions might be made concerning the case put by the respondent.”
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.