Summitt 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “or the settlement of which depends on the value of”

   2 later decisions quote this exact passage
   e.g. Wright v. Comm'r · Garcia v. Comm'r

2. “(A) Foreign currency contract. — The term “foreign currency contract” means a contract— (i) which requires delivery of, or the settlement of which depends on the value of, a foreign currency which is a currency in which positions are also traded through regulated futures contracts, (ii) which is traded in the interbank market, and (iii) which is entered into at arm’s length at a price determined by reference to the price in the interbank market.”

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

3. “a contract—(A) with respect to which the amount required to be deposited and the amount which may be withdrawn depends on a system of marking to market, and (B) which is traded on or subject to the rules of a qualified board or exchange.”

   1 later decision quote this exact passage
   e.g. Garcia v. Comm'r