Jones v. Commissioner’s Empirical Analysis

Citation profile

7 federal appellate · 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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * Congress Intended to limit the deduction under section 22 (b) (2), supra, to the aggregate premiums or consideration paid by the annuitant except where, as in the Deupree and Brodie cases, supra, the annuitant has been in receipt of taxable income in the year in which the annuity was purchased for him by his employer. [Italics supplied.]”

   3 later decisions quote this exact passage
   e.g. Higgs v. Commissioner · Wolfe v. Commissioner

2. ““(2) Annuities, etc. * * * Amounts received as an annuity under an annuity or endowment contract shall be included in gross income; except that there shall be excluded from gross income the excess of the amount received in the taxable year over an amount equal to 3 per cent-um of the aggregate premiums or consideration paid for such annuity (whether or not paid during such year), until the aggregate amount excluded from gross income under this chapter or prior income tax laws in respect of such annuity equals the aggregate premiums or consideration paid for such annuity.””

   2 later decisions quote this exact passage
   e.g. Hackett v. Commissioner · United States v. Drescher

3. ““(B) Employees’ annuities. If an annuity contract is purchased by an employer for an employee under a plan with respect to which the employer’s contribution is deductible under section 23 (p) (1) (B), or if an annuity contract is purchased for an employee by an employer exempt under section 101 (6), the employee shall include in his income the amounts received under such contract for the year received except that if the employee paid any of the consideration for (Iks annuity, the annuity shall be included in his income as provided in sub-paragraph (A) of this paragraph, tho consideration for such annuity being considered the amount contributed by the employee. In all other cases, if the employee’s rights under the contract are nonforfeitable except for failure to pay future premiums, the amount contributed by the employer for such annuity contract on or after such rights become non-forfeitable shall bo included in the income of ilie employee in the year in which tho amount is contributed, which amount together with any amounts contributed by the employee shall constitute the consideration paid for the annuity contract in determining tho amount of the annuity required to be included in the income of the employee under subparagraph (A) of this paragraph.””

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