Wolter Construction Co. v. Commissioner’s Empirical Analysis
634 F.2d 1029 · 1980
Citation profile
7 federal appellate ·
How this case has been cited
Cited by 23 later decisions — most recently May 2017
7 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. § 1501 · 26 U.S.C. § 1504 · 26 U.S.C. § 7482 · 26 U.S.C. § 7805
Relies on New Colonial Ice Co. v. Helvering · Commissioner of Internal Revenue v. South Texas Lumber Co · United States v. Correll · Bingler v. Johnson · National Muffler Dealers Assn., Inc. v. United States
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“1) deferral of gain on intercompany transactions; 2) offsetting gains and losses; 3) tax-free intercompany dividends; 4) greater utilization of NOL and capital loss carryovers; 5) greater utilization of unused investment credits; 6) greater utilization of excess charitable contribution deductions; 7) reduction in gain on sale of a subsidiary; 8) minimizing the minimum tax.”
2 later decisions quote this exact passage · from the majority“the rules will be written by 'masters of the subject,' United States v. Moore, 95 U.S. 760 , 763 (24 L. Ed. 588) (1878), who will be responsible for putting the rule into effect.”
2 later decisions quote this exact passage · from the majority“(c) Limitation on net operating loss carryovers and carrybacks from separate return limitation years— [[Image here]] (2) Computation of limitation. The amount referred to in subparagraph (1) of this paragraph with respect to a member of the group is the excess, if any, of— (i) Consolidated taxable income (computed without regard to the consolidated net operating loss deduction), minus such consolidated taxable income recomputed by excluding the items of income and deduction of such member, over (ii) The net operating losses attributable to such member which may be carried to the consolidated return year arising in taxable years ending prior to the particular separate return limitation year.”
1 later decision 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.