Graham v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate ·

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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Nor do we think it was a reorganization within section 112 (i) (1) (B) * * * [The successor corporation] was not created pursuant to a plan to reorganize any corporate business, but pursuant to a plan to facilitate the liquidation of a corporation. We think that the statute was not intended to include such a transaction under section 112(i) (1) (B), even though it may come within the definition of the statute, and that the question must be answered in the negative.”

   1 later decision quote this exact passage
   e.g. American Mfg. Co. v. Commissioner

2. “When subdivision (B) speaks of a transfer of assets by one corporation to another, it means a transfer made “in pursuance of a plan of reorganization” (section 112 (g)) of corporate business; and not a transfer of assets by one corporation to another in pursuance of a plan having no relation to the business of either * * *.”

   1 later decision quote this exact passage
   e.g. Lewis v. Commissioner