United States v. Donruss Co.’s Empirical Analysis
1969
Citation profile
94 federal appellate · 18 district · 3 state decisions
How this case has been cited
Cited by 232 later decisions (13 by the Supreme Court) — most recently June 2003 · most notably United States v. Generes (1972), Administrator, Federal Aviation Administration v. Robertson (1975)
94 federal appellate · 18 district · 3 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.
Appellate journey
reviewedDonruss Co. v. United States (from Sixth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 531 · 26 U.S.C. § 532 · 26 U.S.C. § 541 · 26 U.S.C. § 551
Relies on Commissioner of Internal Revenue v. Duberstein D Stanton · Eisner v. Macomber · United States v. Wells · Bandy v. United States · Allen v. Trust 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 232 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Unreasonable accumulation determinative of purpose. — For purposes of section 532, the fact that the earnings and profits of a corporation are permitted to accumulate beyond the reasonable needs of the business shall be determinative of the purpose to avoid the income tax with respect to shareholders, unless the corporation by the preponderance of the evidence shall prove to the contrary. [Emphasis supplied.] (b) Holding or investment company.— The fact that any corporation is a mere holding or investment company shall be prima facie evidence of the purpose to avoid the income tax with respect to shareholders. [Emphasis supplied.]”
5 later decisions quote this exact passage · from the majority“Because of the disparity between the corporate tax rates and the higher gradations of the rates on individuals, a corporation may be utilized to reduce significantly its shareholders’ overall tax liability by accumulating earnings beyond the reasonable needs of the business. * * In order to foreclose this possibility of using the corporation as a means of avoiding the income tax on dividends to the shareholders, every Revenue Act since the adoption of the Sixteenth Amendment in 1913 has imposed a tax upon unnecessary accumulations of corporate earnings effected for the purpose of insulating shareholders. [Footnotes omitted.]”
2 later decisions quote this exact passage · from the majority“`is to compel the company to distribute any profits not needed for the conduct of its business so that, when so distributed, individual stockholders will become liable' for taxes on the dividends received.”
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.