Webb v. Commissioner’s Empirical Analysis
1976
Citation profile
4
cited by 4 later decisions
July 1989
most recently cited
2 federal appellate ·
Relationships
Applies 26 U.S.C. § 115
Relies on Knowlton v. Moore · United States v. Joliet & Chicago Railroad · Challenge Mfg. Co. v. Commissioner · Maguire v. Commissioner · Sammons 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The validity of that ruling is doubtful, since the apparent purpose of the provision in section 304(a)(2) is to measure the amount which is to be treated as a dividend to the transferor, and it is unlikely that Congress contemplated treating the constructive distribution to the parent as income to the parent.”
1 later decision quote this exact passage · from the majority“This constructive dividend from the subsidiary to the parent appears to be only for the purpose of increasing the earnings and profits of the parent corporation and apparently is not an intercompany dividend to be included in the gross income of the parent corporation”
1 later decision quote this exact passage · from the majority“part of their stock in the parent corporation to the subsidiary they nevertheless retain ownership and control of both corporations, since the”
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.