Utley v. Commissioner’s Empirical Analysis
1990
Citation profile
9 federal appellate ·
Relationships
Applies 12 U.S.C. § 771 · 26 U.S.C. § 351 · 26 U.S.C. § 453
Relies on Pullman-Standard v. Swint · Commissioner of Internal Revenue v. Duberstein D Stanton · Commissioner of Internal Revenue v. South Texas Lumber Co · Blanton v. General Electric Credit Corp. · 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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[n]o gain or loss shall be recognized if property is transferred to a corporation by one or more persons solely in exchange for stock or securities in such corporation and immediately after the exchange such person or persons are in control ... of the corporation.”
1 later decision quote this exact passage · from the majority“the legal characterization for federal tax purposes of the transactions between the parties . . . is not a question of fact”
1 later decision quote this exact passage · from the majority“that findings of fact not be set aside unless clearly erroneous even where an”
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.