Gooch v. Commissioner’s Empirical Analysis

Citation profile

5 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Exemptions for dependents are matters of legislative grace, and are allowable as deductions in computing taxable income where the conditions prescribed by Congress have been met and satisfied. In the case of dependents, which as defined by section 152 (a) (4) [26 U.S.C. § 152(a) (4)] includes a taxpayer's mother, the exemption is available only if the taxpayer has supplied over half of the dependent's support and the gross income of the dependent in the calendar year was less than $600. [§ 151(e) (1) (A), 26 U.S.C. § 151(e) (1) (A).] Thus, in order to be entitled to a dependency exemption for his mother, petitioner must meet both the support and gross income requirements. (Footnotes omitted). (Emphasis added.) 2 3 The Internal Revenue Code defines gross income as "all income from whatever source derived, including * * * Rents; * * *.”

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

2. “While there is substantial indication that taxpayer did devote considerable of his own time and attention to looking after the properties in which his mother was the owner of interests in common, and possibly may have expended some of his own money in connection with such activities for his mother's benefit, we find no evidence that a business partnership existed or was intended to exist. It was at the most a family arrangement and petitioner was doing those things that by reason of such relationship he would do as his mother's son.”

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

3. “whose gross income for the calendar year in which the taxable year of the taxpayer begins is less than $600 * * *.”

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