Smith v. United States’s Empirical Analysis
460 F.2d 1005 · 1972
Citation profile
9 federal appellate ·
How this case has been cited
Cited by 22 later decisions — most recently June 1996
9 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
Applies 26 U.S.C. § 368 · 26 U.S.C. § 401 (Self-Employed Individuals Tax Retirement Act of 1962) · 26 U.S.C. § 402 · 26 U.S.C. § 501 · 26 U.S.C. § 72
Relies on Georgia v. Wenger · Kimbell-Diamond Milling Co. v. Commissioner · Kimbell-Diamond Milling Co. v. Comm'r · United States v. Johnson · Helvering v. Ashland Oil & Refining Co.
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.
“on account of the employee's separation from the service”
3 later decisions quote this exact passage · from the majority“The only time limitation in the statute requires that the total distributions payable to any employee be paid within one taxable year of the distributee so long as the payment shall be made on account of the separation from the service, and there is no requirement that the separation from the service occur before the distribution occurs or that both events must occur within the same year.” Here the stipulated facts clearly show that the distribution to petitioner was made”
2 later decisions quote this exact passage · from the concurrence“When the plan is adopted by the successor corporation, it is clear that distributions on account of a later decision to terminate the plan are not on account of a separation from service. We need not decide the effect of a stipulation, in a case like Rybacki , that the plan would be continued only a certain length of time and then terminated as a result of the liquidation of the former employer.”
1 later decision quote this exact passage · from the concurrence
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.