Marshall v. Commissioner’s Empirical Analysis

Citation profile

9 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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““In order- for section 107(a) to be applicable it is not necessary that the individual who includes in his gross income compensation for such personal services be the person who rendered such services. For example, a partner who shares in eompensation for such personal services rendered by the partnership may be entitled to the benefits of section 107(a), .notwithstanding that he. took no part-,in the rendering of such services. Likewise, in . community property states, the spouse of a person who renders such personal services may be entitled to the benefits of section 107(a)”. (Italics supplied.)”

   2 later decisions quote this exact passage
   e.g. Hofferbert v. Marshall · McClure v. United States

2. “Since it is the status of the recipient of the income in the year of receipt, and not either his status in prior years, Federico Stallforth, 6 T.C. 140 , nor the identity of the individual who contributed the services, that is made to govern the application of section 107 in its present form, we are satisfied that under the facts of this proceeding petitioner correctly computed his tax by use of its provisions.”

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