Commissioner of Internal Revenue v. John M. Stickney, of the Estate of Henry McK Haserot, and Bonnie C. Haserot’s Empirical Analysis
1968
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 22 later decisions — most recently May 2000
2 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
Applies 26 U.S.C. § 304
Relies on Bradbury v. Commissioner · Meyer v. Commissioner · Charles Swan and Josephine Swan v. Commissioner of Internal Revenue · Neff v. United States · Hann v. Naylor
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[T]he statement in sections 301(a) and 302(d), ‘except as otherwise provided in the chapter’ [or subchapter] of the Code, indicate that Congress made the policy decision that dividend treatment will re- suit froto the application -of Section 302 only if no other provision in the relevant parts of the Code requires treatment. Section 351 has no such limitation. That section is, by its terms, applicable. That section provides for tax treatment of the payment in question in a manner other than and different from the distribution treatment provided for by sections 302(d) and 301. Consequently, the very words in the latter sections preclude dividend treatment in this case.””
3 later decisions quote this exact passage · from the majority“No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation.”
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.