Idol v. Commissioner’s Empirical Analysis
1962
Citation profile
4 federal appellate ·
How this case has been cited
Cited by 25 later decisions — most recently May 2007 · most notably Martin Ice Cream Co. v. Comm'r (1998), Rushing v. Commissioner (1969)
4 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 Douglas v. Willcuts · Wall v. United States · Kimbell-Diamond Milling Co. v. Commissioner · Kimbell-Diamond Milling Co. v. Comm'r · Commissioner of Internal Revenue v. Ashland Oil & Refining Co.
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Not only is it plain from the evidence before us that * * * [the purchaser] had no interest in acquiring any of * * * [the corporation’s] stock, but there is no indication here that Idol had any real desire to dispose of any part of his 42 shares of the corporation’s stock. The only reason the transactions were cast in the form of a sale of stock followed by a redemption was the possibility of obtaining favorable tax treatment. [[Image here]] Not only does the evidence before us fail to disclose that Idol really ■wished to dispose of any of his 42 * * * shares or that * * * [the purchaser] desired to acquire them, but it also fails to indicate that * * * [the corporation] had any reason or purpose to reacquire part of its outstanding shares. Petitioners have not established that * * * [the corporation] had a real intention to reduce its capital or to redeem any part of its outstanding stock. [ 38 T.C. at 460 .]”
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.