Young v. Commissioner’s Empirical Analysis

Citation profile

13 federal appellate · 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In cases like this the taxpayer is at times in a very difficult position in determining in what year to claim a loss. The only safe practice, we think, is to claim a loss for the earliest year when it may possibly be allowed and to renew the claim in subsequent years if there is any reasonable chance of its being applicable to the income for those years.”

   2 later decisions quote this exact passage · from the majority
   e.g. Estate of Fuchs v. Commissioner · Estate of Frank Fuchs, Deceased, Edith Fuchs, and Edith Fuchs, Surviving Wife Individually v. Commissioner of Internal Revenue

2. ““We think the Board and the Commissioner would have been fully justified in finding that the stock became worthless in 1932. Such a trifling realization as $60 which the taxpayer apparently might have obtained as the result of the negotiations in 1936 represented nothing more than nuisance value. * * * “Whether 1932 or 1936 be taken as the time when the stock became worthless, in each year there was an identifiable event— in the first bankruptcy, and in the second the expiration of the option in Imco.” 123 F.2d 600 .'”

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