Coyle v. United States’s Empirical Analysis
415 F.2d 488 · 1968
Citation profile
1 federal appellate ·
How this case has been cited
Cited by 8 later decisions — most recently July 1989
1 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. § 302 · 26 U.S.C. § 304 · 26 U.S.C. § 318
Relies on Brown Shoe Co. v. Commissioner · Bradbury v. Commissioner · Ballenger v. United States · Levin v. Commissioner · Wiseman v. United States
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“as a capital contribution even though it does not come from an actual shareholder. It should be stressed that appellee raises no specter of adverse effects from treating the shares as a capital contribution either on the non-shareholder or the corporation. The only point made is that the Code's treatment as applied here is”
2 later decisions quote this exact passage · from the majority“* * * determinations as to whether the acquisition is, by reason of section 302(b), to be treated as a distribution in part or full payment in exchange for the stock shall be made reference to the stock of the issuing corporation.”
1 later decision quote this exact passage · from the majority“The rules of constructive ownership rest on certain assumptions which are readily supported in the everyday conduct of affairs. * * Tax administration would be severely handicapped if the rules applied only as presumptions * * *.”
1 later decision 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.