The Covered Wagon, Inc., Grace D. Ryan, Transferee, Mina Benson, Transferee, Fritz W. Benson, Transferee v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. The Covered Wagon, Inc., Grace D. Ryan, Transferee, Mina Benson, Transferee, Fritz W. Benson, Transferee’s Empirical Analysis
369 F.2d 629 · 1966
Citation profile
14 federal appellate · 1 district ·
How this case has been cited
Cited by 27 later decisions (1 by the Supreme Court) — most recently July 1997 · most notably Central Tablet Manufacturing Co. v. United States (1974), United States v. Timmons (1982)
14 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
Applies 26 U.S.C. § 337 · 26 U.S.C. § 7482
Relies on United States v. Miller · Fribourg Navigation Company v. Commissioner of Internal Revenue · Kieselbach v. Commissioner · Konigsberg v. State Bar · Towanda Textiles, Inc. 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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“of the corporation's real property, by condemnation, occurred at the time the declaration of taking was filed in court and a deposit made therein to cover estimated compensation for the acquired property, that is, at the time title to the property vested in the United States, under the Federal Declaration of Taking Act, supra. As heretofore stated, this occurred on July 6, 1956, whereas, the corporation's shareholders did not adopt a plan of complete liquidation until January 2, 1957, nearly six months thereafter. Consequently, we hold that the”
2 later decisions quote this exact passage“Upon the filing said declaration of taking and of the deposit in the court, to the use of the persons entitled thereto, of the amount of the estimated compensation stated in said declaration, title to the said lands in fee simple absolute or such less estate or interest therein as is specified in said declaration, shall vest in the United States.. ..”
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.