Sedlack v. Commissioner’s Empirical Analysis

Citation profile

8 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The statute requires that the compensation for services performed prior to the taxable year ‘would have been paid prior to the taxable year except * * *’. These employees were not entitled to the additional payment for their services in any taxable year except the one when the contract between the Chidester estate and its creditors was discharged by performance. * * * But there was no extra compensation due them until the completion of that course. That was in 1946. It was not until that time that they were entitled to the extra compensation. Then they got it. It is inescapable that what they received was subject to income taxation then.””

   1 later decision quote this exact passage
   e.g. Posner v. Kavanagh

2. “The treasury regulation precludes back pay for past services in the absence of a 'prior agreement or legal obligation'.”

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

3. “of no consequence that they were not made as a result of a 'legal obligation', as found by the court.”

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