Greene v. Commissioner’s Empirical Analysis

Citation profile

2 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Art. 1566. Exchange of property which results in no gain or loss: Where property is exchanged for other property, even if the property received in exchange has a readily realizable market value, no gain or loss is recognized— “ (a) Where property held for investment is exchanged for other property of a like kind or where property held for productive use in trade or business is exchanged for other property of a like use. The words ‘like kind’ are defined as having reference to the nature or character of the property and not its grade or quality. Therefore, under this paragraph, no gain or loss is realized, by one other than a dealer from the exchange of real estate for real estate, or from the exchange of evidences of indebtedness (such as bonds and notes) for evidences of indebtedness, or from the exchange of shares of stoek for other shares of stock; but one kind or class of property may not, under this paragraph, be exchanged for property of a different kind or class, as shares of stoek for bonds or real estate for personal property.””

   1 later decision quote this exact passage · from the dissent
   e.g. Edson v. Lucas