Tyree 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “In this posture of the ruling cases we adhere to the position taken by us in the Mnookin and Waldman cases and hold that, under the facts here present, the tax year of the partnership, of which decedent was a member, did not end at his death and that no part of the partnership income for the period March 1, 1946 to August 21, 1946 (the date of death), should be included in decedent's final return for the period January 1, 1946, to August 21, 1946.”

   1 later decision quote this exact passage · from the dissent
   e.g. Ollendorff v. Commissioner

2. “The question at issue has been before the courts on numerous occasions and the rulings are not uniform. In Estate of Hunt Henderson, 4 T.C. 1001 , this Court held, in effect, that '* * * partnership losses of decedent for the period of January 1 to June 21, 1939 [the latter being the date of death], were”

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

3. “not properly includible in respect of the taxable period in which falls the date of his death”

   1 later decision quote this exact passage · from the dissent
   e.g. Commissioner of Internal Revenue v. Tyree's Estate