Lum v. Commissioner’s Empirical Analysis

Citation profile

2 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(a) Personal Services. - If at least 80 per centum of the total compensation for personal services covering a period of thirty-six calendar months or more (from the beginning to the completion of such services) is received or accrued in one taxable year by an individual or a partnership, the tax attributable to any part thereof which is included in the gross income of any individual shall not be greater than the aggregate of the taxes attributable to such part had it been included in the gross income of such individual ratably over that part of the period which precedes the date of such receipt or accrual.”

   2 later decisions quote this exact passage
   e.g. Christie v. Commissioner · Williams v. Commissioner

2. “In the case of services of a homogeneous nature and covering a continuous period, it took more in the Nast [Julia C. Nast, 7 T. C. 432 ] case than the mere rendering of a bill to mark the beginning of the period of services, just as here it takes more than the rendering of an account to mark their end.”

   1 later decision quote this exact passage
   e.g. Loew v. Commissioner

3. “unless the services themselves are divisible, the compensation received therefor, regardless of source, must be lumped together.”

   1 later decision quote this exact passage
   e.g. Lesser v. Commissioner