Irving Gordon and Margaret Gordon v. Cmmissioner of Intenal Revenue’s Empirical Analysis
1970
Citation profile
15 federal appellate · 1 district ·
How this case has been cited
Cited by 27 later decisions — most recently May 1995 · most notably Redding v. Commissioner (1980), Berry Petroleum Co. v. Commissioner (1995)
15 federal appellate · 1 district ·
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 Eisner v. Macomber · United States v. Equitable Life Assurance Society · Helvering v. Southwest Consolidated Corp. · Palmer v. Commissioner · Commissioner v. Gordon
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Although a number of cases have pointed to a complete identity of shareholders before and after the transaction as evidence that the corporation had undergone a mere change in form, see, e. g., Associated Machine v. Commissioner of Internal Revenue, 403 F.2d 622, 625 (9 Cir. 1968); Estate of Stauffer v. Commissioner of Internal Revenue, 403 F.2d 611, 618 (9 Cir. 1968); Davant v. Commissioner of Internal Revenue, 366 F.2d 874, 884 (5 Cir. 1966), cert. denied, 386 U.S. 1022 , 87 S.Ct. 1370 , 18 L.Ed.2d 460 (1967), it is not clear thus far whether' such an identity is an indispensable condition to the invocation of Section 368(a)(1)(F).””
2 later decisions quote this exact passage · from the majority“* * * a divisive reorganization should not qualify as a mere change in form for purposes of Section 354 unless it meets the standards of either Section 354 (b) or Section 355. [ 424 F. 2d at 385 .]”
2 later decisions quote this exact passage · from the majority“not essentially equivalent to a dividend”
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.