Wright v. United States’s Empirical Analysis
482 F.2d 600 · 1973
Citation profile
12 federal appellate ·
How this case has been cited
Cited by 30 later decisions (1 by the Supreme Court) — most recently August 2021 · most notably Commissioner v. Clark (1989), Jones v. Diamond (1979)
12 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. § 1346 · 26 U.S.C. § 302 · 26 U.S.C. § 318 · 26 U.S.C. § 346 · 26 U.S.C. § 354 · 26 U.S.C. § 356
Relies on Costello v. United States · Commissioner of Internal Revenue v. Bedford's Estate · United States v. Davis · Abdul v. United States · Sachs 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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(2) 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.” [Emphasis added.]”
5 later decisions quote this exact passage · from the majority“not essentially equivalent to a dividend”
3 later decisions quote this exact passage · from the majority“distribution is substantially disproportionate with respect to the shareholder.”
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.