Clement O. Dennis and Genia Lee Dennis v. Commissioner of Internal Revenue’s Empirical Analysis
1973
Citation profile
16 federal appellate ·
How this case has been cited
Cited by 32 later decisions — most recently April 2017 · most notably Roth Steel Tube Co. v. Commissioner (1986), Warren Jones Co. v. Commissioner (1975)
16 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 Commissioner of Internal Revenue v. South Texas Lumber Co · Industrial National Bank of Rhode Island v. Wingate Corp. · Commissioner v. Brown · Burnet v. Logan · General Utilities & Operating Co. v. Helvering
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Subject to the exceptions contained in section 453(dX4) and paragraph (c) of this section, the entire amount of gain or loss resulting from any disposition or satisfaction of installment obligations, computed in accordance with section 453(d), is recognized in the taxable year of such disposition or satisfaction and shall be considered as resulting from the sale or exchange of the property in respect of which the installment obligation was received by the taxpayer.””
2 later decisions quote this exact passage · from the majority“"(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.””
2 later decisions quote this exact passage · from the majority“"If property was acquired on or after June 22,1954, by a corporation— "(1) in connection with a transaction to which section 351 (relating to transfer of property to corporation controlled by transferor) applies, or "(2) as paid-in surplus or as a contribution to capital, "then the basis shall be the same as it would be in the hands of the transferor, increased in the amount of gain recognized to the transferor on such transfer.””
2 later decisions 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.