Mills v. Commissioner’s Empirical Analysis

Citation profile

5 federal appellate · 1 district ·

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

1. “(C) the acquisition by one corporation, in exchange solely for all or a part of its voting stock (or in exchange solely for all or a part of the voting stock of a corporation which is in control of the acquiring corporation), of substantially all of the properties of another corporation, but in determining whether the exchange is solely for stock the assumption by the acquiring corporation of a liability of the other, or the fact that property acquired is subject to a liability, shall be disregarded”

   2 later decisions quote this exact passage · from the majority
   e.g. Heverly v. Commissioner · Arden S. Heverly and Sophia S. Heverly v. Commissioner of Internal Revenue

2. “We construe the word 'solely' as meaning precisely what it purports to mean, namely that the receipt by the stockholders of an acquired corporation of any consideration whatsoever other than voting stock forbids a transaction from being a reorganization as defined under section 368(a)(1)(B) . . . . We cannot assume that Congress was incapable of expressing a grant of leeway when that was its purpose.”

   1 later decision quote this exact passage · from the majority
   e.g. Chapman v. Commissioner

3. “The Supreme Court held that the $106,680 was other consideration and alternatively that certain warrants issued were also not voting stock.”

   1 later decision quote this exact passage · from the majority
   e.g. Arden S. Heverly and Sophia S. Heverly v. Commissioner of Internal Revenue