Bennett v. United States’s Empirical Analysis
427 F.2d 1202 · 1970
Citation profile
3 federal appellate ·
Relationships
Applies 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983)
Relies on Southern Pac Co v. Lowe · New York Central Railroad v. Board of Public Utility Commissioners · Gilbert v. California · Commissioner v. Phipps · Foster 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““General rule. — Except as otherwise provided in this section, on the distribution of property by a corporation with respect to its stock, the earnings and profits of the corporation (to the extent thereof) shall be decreased by the sum of— “(1) the amount of money, “(2) the principal amount of the obligations of such corporation, and “(3) the adjusted basis of the other property, so distributed.” (emphasis added.)”
1 later decision quote this exact passage · from the majority“portion of the [capital] account equal to the percentage of the corporation's total outstanding shares [20] represented by the number of shares redeemed [19],”
1 later decision quote this exact passage · from the majority“'earnings and profits' ... is a tax, not an economic concept”
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.