May v. United States’s Empirical Analysis
644 F.2d 578 · 1981
Citation profile
1 federal appellate ·
Relationships
Applies 26 U.S.C. § 1371 · 26 U.S.C. § 1372 · 26 U.S.C. § 1374 · 26 U.S.C. § 1504
Relies on Commissioner of Internal Revenue v. National Alfalfa Dehydrating and Milling Company
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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“and before the close of the tax years in question precludes reliance on sec. 1371(d) . We disagree, however, with the District Court's conclusion that Oldmar's corporate identity should be disregarded. Florida Downs was free to organize its affairs as it chose. It did so in a manner which made it a member of an affiliated group. Having made that decision, the shareholders of Florida Downs”
1 later decision quote this exact passage · from the majority“(1) has not begun business at any time on or after the date of its incorporation and before the close of such taxable year, and (2) does not have taxable income for the period included within such taxable year.”
1 later decision quote this exact passage · from the majority“within the meaning of sec. 1371(d) . * * * That Oldsmar may have become inactive after its acquisition by Florida Downs [the subchapter S corporation] is irrelevant ; the beginning of business”
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.