Paulsen v. Commissioner’s Empirical Analysis
1983
Citation profile
1 federal appellate · 1 state decisions
How this case has been cited
Cited by 6 later decisions (1 by the Supreme Court) — most recently June 2006
1 federal appellate · 1 state decisions
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.
Appellate journey
Relationships
Applies 26 U.S.C. § 1001 · 26 U.S.C. § 354 · 26 U.S.C. § 591 · 26 U.S.C. § 7701
Relies on Strong v. United States · Le Tulle v. Scofield · Helvering v. Minnesota Tea Co. · David Levell W. v. California · John A. Nelson Co. v. Helvering
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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in Commerce. In exchange for this stock petitioners received passbook savings accounts and time certificates of deposit in Citizens. Relying on 26 U.S.C. §§ 354(a)(1) and 368(a)(1)(A), they did not report the gain they realized on their 1976 federal income tax return because they considered the merger to be a tax-free reorganization. 3 Before it ceased to exist, Commerce was a state-chartered savings and loan association incorporated and operated under Washington State law. It was authorized to issue”
1 later decision quote this exact passage · from the majority“are in reality indistinguishable from ordinary savings accounts and are essentially the equivalent of cash.”
1 later decision quote this exact passage · from the majority“despite certain formal equity characteristics”
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.