Ryan v. Harrison’s Empirical Analysis

Citation profile

5 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * [i]t must be remembered that the purpose of the statute requiring claims for refund to be filed within a stated time limit is to give the government notice of the pending claim and thus protect it from stale demands. * * * The first claim must therefore give notice of the subject matter of the second. * * It is considered that such notice has been given when the examination necessary to acceptance or rejection of the first claim would necessarily reveal the factual situation to which the second claim relates, or the grounds on which it relies.”

   2 later decisions quote this exact passage · from the majority
   e.g. Pearl Assurance Co. v. United States · Pearl Assurance Co. v. United States

2. “such net operating loss shall be a net operating loss carry-back for each of the two preceding taxable years, except that the carry-back in the case of the first preceding taxable year shall be the excess, if any, of the amount of such net operating loss over the net income for the second preceding taxable year.”

   1 later decision quote this exact passage · from the majority
   e.g. Pearl Assurance Co. v. United States