Sneed v. Commissioner’s Empirical Analysis

Citation profile

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

1. “As petitioner is an income beneficiary and the pertinent provisions of the trust instrument do not direct whether the trustee or the beneficiaries shall be allowed the depletion deduction, she is entitled to an apportionment of the depletion allowance. William Fleming, Trustee, 43 B.T.A. 229 , affd. (C.A. 5, 1941) 121 F. 2d 7 . She is entitled, however, to only such portion of the depletion allowance as is indicated by her proportion of the trust income. Sada G. Wilson Blake, supra.”

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

2. “Bearing heavily against petitioner because she has failed to meet her burden of proof as to amount, but determining the matter as best we can, from the evidence before us which merely is that some amount of trust income was from depletable property, we have concluded and found as a fact that petitioner has an allowable depletion deduction in the amount of $100 for each of the taxable years 1942 and 1943.”

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

3. “* * * (2) whether petitioner is entitled to deduct statutory percentage depletion on a portion of the $15,000 paid to her, pursuant to a codicil attached to the will of J. T. Sneed, Jr., in each of the years 1942 and 1943 by the J. T. Sneed, Jr., trust estate;”

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