Mabel Elevator Co. v. Commissioner’s Empirical Analysis

Citation profile

3 federal appellate · 3 district ·

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

1. “for the purpose of assuring the taxpayer, who has made an honest return, that after such period his tax liability will not be reopened; otherwise the business of the country would always have before it the threat of additional taxes against the income of years long past.”

   2 later decisions quote this exact passage
   e.g. Indiana Rolling Mills Co. v. Commissioner · Atlantic Land & Improvement Co. v. United States

2. “The return filed purported to be made In accordance with the law; it purported to and did include the income of the taxpayer for the period in question. In the absence of any evidence or claim that such return was false or fraudulent with intent to evade tax, it became the duty of the Commissioner to determine, within the time prescribed by law, whether or not such return was erroneous in any respect.”

   1 later decision quote this exact passage
   e.g. Bastrop Mercantile Co. v. Commissioner

3. “The deficiency letter from which this appeal was taken was mailed to the taxpayer more than five years after the return was filed on April 21, 1919, and the limitation of time within which taxes must be assessed had expired.”

   1 later decision quote this exact passage
   e.g. John Wanamaker Philadelphia v. Commissioner