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← 46 TC 604 - Raich v. Commissioner

Raich v. Commissioner’s Empirical Analysis

1966

Citation profile

22
cited by 22 later decisions
November 1997
most recently cited

7 federal appellate ·

How this case has been cited

Cited by 22 later decisions — most recently November 1997

7 federal appellate ·

1501966197019801990decided

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. § 351

Relies on Watson v. Commissioner · Helvering v. Cement Investors, Inc. · Rosenberg v. United States · Williams v. McGowan · Camp Wolters Enterprises, Inc. 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “(a) General Rule. — No gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control (as defined in section 368(c)) of the corporation. For purposes of this section, stock or securities issued for services shall not be considered as issued in return for property. (b) Receipt of Property. — If subsection (a) would apply to an exchange but for the fact that there is received, in addition to the stock or securities permitted to be received under subsection (a), other property or money, then— (1) gain (if any) to such recipient shall be recognized, but not in excess of— (A) the amount of money received, plus (B) the fair market value of such other property received; and (2) no loss to such recipient shall be recognized.”
    1 later decision quote this exact passage
  2. “[W]e are not unmindful that the result reached may conflict with the well-established intent of Congress to foster tax-free reorganizations.”
    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.