Wolfers v. Commissioner’s Empirical Analysis
1978
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 11 later decisions — most recently March 2007
2 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. § 1034
Relies on Detroit Edison Co. v. Commissioner · Brown Shoe Co. v. Commissioner · United States v. Chicago, Burlington & Quincy Railroad · Hearn v. Commissioner · Glendinning, McLeish & Co. 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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(c) Special Rule for Certain Contributions to Capital.— (1) Property other than money. — Notwithstanding subsection (a)(2), if property other than money— (A) is acquired by a corporation, on or after June 22,1954, as a contribution to capital, and (B) is not contributed by a shareholder as such, then the basis of such property shall be zero. (2) Money. — Notwithstanding subsection (a)(2), if money— (A) is received by a corporation, on or after June 22,1954, as a contribution to capital, and (B) is not contributed by a shareholder as such, then the basis of any property acquired with such money during the 12-month period beginning on the day the contribution is received shall be reduced by the amount of such contribution. The excess (if any) of the amount of such contribution over the amount of the reduction under the preceding sentence shall be applied to the reduction (as of the last day of the period specified in the preceding sentence) of the basis of any other property held by the taxpayer. The particular properties to which the reductions required by this paragraph shall be allocated shall be determined under regulations prescribed by the Secretary or his delegate. (The subsequent amendment of this provision by sec. 1906(b)(13)[sic](A), Tax Reform Act of 1976, Pub. L. 94-455,90 Stat. 1834, does not affect the instant case.)”
1 later decision quote this exact passage“We hold, accordingly, that the only basis HLW has for depreciation purposes in its new improvements is the basis it had in the assets it lost. No new qualified investment, therefore, was made for investment tax credit purposes. Sec. 46(c)(1). Accordingly, we need not reach the issue whether certain new assets constitute section 38 property.”
1 later decision quote this exact passage
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.