Mitchell v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate · 1 state decisions

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

1. “and addresses events that may defeat the property interest that has passed to the donee organization. It provides that a deduction will not be disallowed merely because on the date of the gift there is the possibility that the interest will be defeated so long as on that date the possibility of defeat is so remote as to be negligible. Paragraph (g)(6) is entitled”

   2 later decisions quote this exact passage
   e.g. Carpenter v. Comm'r · 2013 T.C. Memo. 204 - Mitchell v. Comm'r

2. “and recognizes that after the donee organization's receipt of an interest in property, an unexpected change in the conditions surrounding the property can make impossible or impractical the continued use of the property for conservation purposes. Subdivision (i) of paragraph (g)(6) provides that those purposes will nonetheless be treated as protected in perpetuity if the restrictions limiting use of the property for conservation purposes”

   1 later decision quote this exact passage
   e.g. 2013 T.C. Memo. 204 - Mitchell v. Comm'r

3. “Considine v. Commissioner , 74 T.C. at 967 (emphasis added) (quoting DeJong v. Commissioner , 36 T.C. at 899 ). While a taxpayer is generally not allowed a charitable contribution deduction for a gift of property consisting of less than an entire interest in that property, an exception is made for a”

   1 later decision quote this exact passage
   e.g. RP Golf, LLC v. Comm'r