Keeney v. Commissioner’s Empirical Analysis

Citation profile

10 federal appellate · 3 district ·

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

1. ““It is true that some liberality is accorded to the taxpayer, and this has taken the form of requiring that worthlessness be established by some identifiable event. United States v. S. S. White Dental Mfg. Co., 274 U.S. 398, 401 , 47 S.Ct. 598 , 71 L.Ed. 1120 . This does not mean, however, that the taxpayer can himself fix the identifiable event by selling for a nominal amount stock that, had become worthless in a prior year. De Loss v. Commissioner, 2 Cir., 28 F.2d 803 . Nor can he postpone his claim of loss until only an ‘incorrigible optimist’ would fail to know that the stock had become worthless at an earlier date. A finding of worthlessness depends on all the facts of the particular case reasonably leading to that conclusion.””

   1 later decision quote this exact passage · from the majority
   e.g. Woodward v. United States