Reef Corp. v. Commissioner’s Empirical Analysis
1966
Citation profile
36 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 66 later decisions — most recently September 2014 · most notably Redwing Carriers, Inc. v. Tomlinson (1968), Waterman Steamship Corp. v. Commissioner (1970)
36 federal appellate · 1 district · 1 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.
Relationships
Relies on Gregory v. Helvering · Commissioner of Internal Revenue v. Court Holding Co · Commissioner v. Brown · Helvering v. Southwest Consolidated Corp. · Bazley 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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) In general.' — For purposes of parts I and II and this part, the term “reorganization” means— ******* (F) a mere change in identity, form, or place of organization, however effected.”
3 later decisions quote this exact passage · from the majority“[Strong] was a mere conduit in a preconceived and prearranged unified plan to redeem the stock of the Favrot group in Reef Fields. His activity was but a step in the plan. He carried out a sales contract already entered into between the corporations. He assumed no risk, incurred no personal liability, paid no expenses and obtained only bare legal title to the stock. There was an insufficient shifting of economic interests to Strong. It is settled that under such circumstances substance must be given effect over form for federal tax purposes. The holding of the Tax Court in this regard was not clearly erroneous.”
2 later decisions quote this exact passage · from the majority““The Tax Court’s position might have more force if the change in proprietary interests were to new persons and less than 50% of the former stockholders’ interest in the old corporation remained in the new corporation. Then the change begins to look like a sale of the assets to a new and legally separate entity followed by a bona fide liquidation. * * *” ( 368 F. 2d at 137 .)”
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.