Parsons v. Commissioner’s Empirical Analysis

Citation profile

1 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The cash surrender value is the market value only of a surrendered policy and to maintain that it represents the true value of the policy is to confuse its forced liquidation value at an arbitrary figure with the amount realizable in an assumed market where such policies are frequently bought and sold. Moreover, such an argument overlooks the value to be placed upon the investment in the insured's life expectancy and the protection afforded his dependents.”

   1 later decision quote this exact passage
   e.g. Gravois Planing Mill Co. v. Commissioner

2. “Since the only value realizable at any time prior to petitioner's death was and will be the cash surrender value, the petitioner urges that this would represent the fair market value of the new policy. We do not agree.”

   1 later decision quote this exact passage
   e.g. Gravois Planing Mill Co. v. Commissioner

3. “agreed upon by the petitioner as a willing buyer and the insurance company as a willing seller”

   1 later decision quote this exact passage
   e.g. Gravois Planing Mill Co. v. Commissioner