Wilson v. Commissioner’s Empirical Analysis
1966
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 25 later decisions — most recently November 1983 · most notably Atlas Tool Co. v. Commissioner (1980), Abegg v. Commissioner (1968)
8 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
Relies on Costello v. United States · United States v. Utah Construction & Mining Co. · Minnesota Tea Co. v. Helvering · Commissioner of Internal Revenue v. Bedford's Estate · Goodall-Sanford, Inc. v. United Textile Workers, A. F. L. Local 1802
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the stockholders of a corporation to withdraw its earnings and profits in the form of liquid or investment or other nonessential assets, to continue in the same relationship to 'the business,' and to avoid tax at ordinary income rates on what is essentially a dividend.”
2 later decisions quote this exact passage“(a) Gain on Exchanges.— (1) Recognition of gain. — If— ,(A) section 354 or 355 would apply to an exchange but for the fact that (B) the property received in the exchange consists not only of property permitted by section 354 or 355 to be received without the recognition of gain but also of other property or money, then the gain, if any, to the recipient shall be recognized, but in an amount not in excess of the sum of such money and the fair market value of such other • property. (2). Treatment as dividend. — If an exchange is described in paragraph (li) but has the effect of the distribution of a dividend, then there shall be treated as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in. excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be treated as gain from the exchange of property.”
1 later decision quote this exact passage“Treatment as dividend. If an exchange is described in paragraph (1) but has the effect of the distribution of a dividend, then there shall be treated as a dividend to each distributee such an amount of the gain recognized under paragraph (1) as is not in excess of his ratable share of the undistributed earnings and profits of the corporation accumulated after February 28, 1913. The remainder, if any, of the gain recognized under paragraph (1) shall be treated as gain from the exchange of property.”
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.