Leininger 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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Even if petitioner’s wife be considered as a subpartner or in partnership solely with her husband, the incidence of the taxing statute would not thereby be avoided, for the income earned on the one-half interest standing in the name of O. P. Leininger would first be income to him, taxable as such before its division with his wife. See Ormsby McKnight Mitchel, 1 B. T. A. 143; aff'd., 9 Fed. (2d) 414; 15 Fed. (2d) 287.”

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

2. “The principal question for determination in these cases is whether petitioner is liable for tax on all of the profits of a one-half interest in a partnership or whether, under the facts his wife may return for taxation one-half of such profits.”

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

3. “a full equal partner with him in his interest in the partnership”

   1 later decision quote this exact passage
   e.g. Burnet v. Leininger