Parkey v. Commissioner’s Empirical Analysis

Citation profile

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

1. “The gist of this instrument is that, for a payment of $175,000, the oil company was given the right to prospect and produce oil for a maximum term of 50 years under the conditions and upon the payments set forth therein. Whether this instrument can be described by any defined legal terms — such as lease, license, etc., — it is certain that it is only a limited grant of a right in respect to land and for a limited period of time by one having the fee and possession. Such can not be denominated a sale in the ordinary sense of that word, and there is no reason to construe section 206 as using “ sale ” in any other sense. The wording and the legislative history of section 206 are clear that it was intended to apply to “ sales ” in the sense of conveyance of title to property, not of the creation of privileges or estates or rights in property for a limited period of time.”

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