DeCleene v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate ·

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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “These regulations, with their provisions for use of third-party 'qualified intermediaries' as accommodation titleholders, who will not be considered the taxpayer's agent in doing the multiparty deferred exchanges permitted by the regulations, have encouraged the growth of a new industry of third-party exchange facilitators.”

   1 later decision quote this exact passage · from the majority
   e.g. Estate of Bartell v. Comm'r

2. “[i]n substance, * * * [the taxpayer] never disposed of the Lawrence Drive property and remained its owner during the 3-month construction period because the transfer of title to WLC never divested * * * [the taxpayer] of beneficial ownership.”

   1 later decision quote this exact passage · from the majority
   e.g. Estate of Bartell v. Comm'r

3. “fact that any real estate involved is improved or unimproved is not material, for that fact relates only to the grade or quality of the property and not to its kind or class.”

   1 later decision quote this exact passage · from the majority
   e.g. Estate of Bartell v. Comm'r