Common sense versus judicial legislation being the review of a law recently enacted by the Supreme Court of Massachusetts - Sargent, John Osborne (G.P. Putnam, 1871)
"The case referred to is that of Minot v. Paine and others, reported in 99 Mass. 101, and decided by the Supreme Court of Massachusetts in the year 1868."–P. 6. - Attributed to: John Osborne Sargent. Cf. NUC pre-'56. - OCLC, 31372597. - Reproduction of original from Harvard Law School Library. - The rule is "to regard cash dividends, however large, as income, and stock dividends, however made, as capital."–P. 12