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← 42 TC 914 - Wilson v. Commissioner

Wilson v. Commissioner’s Empirical Analysis

1964

Citation profile

14
cited by 14 later decisions
June 1997
most recently cited

4 federal appellate · 2 district ·

How this case has been cited

Cited by 14 later decisions — most recently June 1997

4 federal appellate · 2 district ·

701964197019801990decided

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 Gideon v. Cochran · Coady v. Commissioner · Prassinos v. District Director, Immigration & Naturalization Service · United States v. Marett · Bonsall v. Commissioner

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

  1. “The answer to that position is that in the present case we have found that there was no plan or intention to achieve any such result and no attempt to do so has in fact been made.”
    2 later decisions quote this exact passage
  2. “obtain such cash or property or the cash equivalent thereof, either by selling the distributed stock or liquidating the corporation, thereby converting what would otherwise be dividends taxable as ordinary income into capital gain . . . .”
    1 later decision quote this exact passage
  3. “such trade or business was not acquired within * * * [the 5-year period ending on the date of distribution] in a transaction in which gain or loss was recognized in whole or in part, * * * [Emphasis added.]”
    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.