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← 444 F.2d 677 - Winn-Dixie Montgomery, Inc. v. United States

Winn-Dixie Montgomery, Inc. v. United States’s Empirical Analysis

444 F.2d 677 · 1971

Citation profile

74
cited by 74 later decisions
1
cited 1 times by the Supreme Court
1
states following
August 2003
most recently cited

26 federal appellate · 1 district · 1 state decisions

How this case has been cited

Cited by 74 later decisions (1 by the Supreme Court) — most recently August 2003 · most notably Buffalo Tool & Die Mfg. Co. v. Commissioner (1980), Newark Morning Ledger Co. v. United States (1993)

26 federal appellate · 1 district · 1 state decisions

3301971198019902000decided

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. § 167

Relies on Cohan v. Commissioner · Scalza v. United States · Roberts v. Florida · Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennan · Carter v. Campbell

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

  1. “No decision holds or suggests that such a one-sided, uncommunicated apportionment of a sales price is conclusive on the taxing authorities, and it is obvious that it would be dangerous and unfair to lay down that categorical rule. The whole trend of the law in this area is against binding the Revenue Service by such a secret, unilateral, subjective allocation which is not carried over into the agreement.”
    2 later decisions quote this exact passage
  2. “is bottomed on the ability of the acquired business to generate sales without any interruption because of the takeover.”
    2 later decisions quote this exact passage
  3. “transfer enables the purchaser to step into the shoes of the seller.”
    2 later decisions 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.