Squire v. Students Book Corp.’s Empirical Analysis

Citation profile

23 federal appellate · 1 district · 2 state decisions

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

1. “a close and intimate relationship to the functioning of the College itself.”

   3 later decisions quote this exact passage · from the majority
   e.g. Redlands Surgical Servs. v. Commissioner · University Hill Foundation v. Commissioner

2. “(b) If a subsidiary organization of a tax-exempt organization would itself be exempt on the ground that its activities are an integral part of the exempt activities of the parent organization, its exemption will not be lost because, as a matter of accounting between the two organizations, the subsidiary derives a profit from its dealings with its parent organization, for example, a subsidiary organization which is operated for the sole purpose of furnishing electric power used by its parent organization, a tax-exempt educational organization, in carrying on its educational activities. However, the subsidiary organization is not exempt from tax if it is operated for the primary purpose of carrying on a trade or business which would be an unrelated trade or business (that is, unrelated to exempt activities) if regularly carried on by the parent organization. For example, if a subsidiary organization is operated primarily for the purpose of furnishing electric power to consumers other than its parent organization (and the parent’s tax-exempt subsidiary organizations), it is not exempt since such business would be an unrelated trade or business if regularly carried on by the parent organization. Similarly, if the organization is owned by several unrelated exempt organizations, and is operated for the purpose of furnishing electric power to each of them, it is not exempt since such business would be an unrelated trade or business if regularly carried on by any one of the tax-exemp”

   2 later decisions quote this exact passage · from the majority
   e.g. Geisinger Health Plan v. Commissioner · Redlands Surgical Servs. v. Commissioner

3. ““or [as the 2nd Circuit.court said], to put the matter another way, if the only purpose of the enterprise is to devote its profits to charitable or educational ends the exemption has been usually held to attach. It has been thought that the exemption, unlike exemption statutes generally, should be liberally construed because of the gain to the public through the encouragement of charity. In two very recent decisions, reaching opposite conclusions, namely, United States v. Community Services, 4 Cir., 189 F.2d 421 , and C. F. Mueller Co. v. C. I. R., 3 Cir., 190 F.2d 120 , the subject has been extensively reviewed and the authorities cited and discussed. We think it unnecessary again to plow this field, more particularly since Congress in the Revenue Act of 1950 has declared a different rule applicable for taxable years commencing after December 31, 1950.””

   2 later decisions quote this exact passage · from the majority
   e.g. Riker v. Commissioner · Peggy Lou Riker and Freda H. Grassmee v. Commissioner of Internal Revenue