United States v. Hvoslef’s Empirical Analysis

Citation profile

73 federal appellate · 33 district · 41 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 299 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““An act extending the time for the repayment of certain war revenue taxes erroneously collected. “Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, that all claims for the refunding of any internal tax alleged to have been erroneously or illegally assessed or collected under the provisions of section 29 of the act of Congress approved June 13, 1898, known as the war revenue tax, or of any sums alleged to have been excessive, or in any manner wrongfully collected under the provisions of said act may be presented to the Commissioner of Internal Revenue on or before the first day of January, 1914, and not thereafter. “Sec. 2. That the Secretary of the Treasury is hereby authorized and directed to pay, out of any moneys of the United States not otherwise appropriated, to such claimants as have presented or shall hereafter so present their claims, and shall establish such erroneous or illegal assessment and collection, any sums paid by them or on their account or in their interest to the United States under the provisions of the act aforesaid. “Approved July 27, 1912.””

   2 later decisions quote this exact passage · from the majority
   e.g. Rand v. United States · Hunnewell v. Gill

2. ““A charter party may be a contract for the lease of the vessel, or for a special service to be rendered by the owner of the vessel. Where, as is very frequently the case, the shipowner undertakes to carry a cargo, to be provided by the charterer, on a designated voyage, the arrangement is, in contemplation of law, a mere contract of affreightment. By such a charter, the shipowner is the carrier of the goods transported by the ship, ‘for the reason that the charter party is a mere covenant for the conveyance of the merchandise or the performance of the stipulated service.’ Marcardier v. Chesapeake Ins. Co., 8 Cranch, 39, 49, 50 , 3 L.Ed. 481, 484 ; Reed v. United States, 11 Wall. 591, 600, 601 , 20 L. Ed. 220 ; Leary v. United States, 14 Wall. 607, 610 , 20 L.Ed. 756 ; Richardson v. Winsor, 3 Cliff. 395, 399 , Fed.Cas.No.11,795; The T. A. Goddard, 12 Fed. 174, 178 ; 1 Parsons, Shipping, p. 278.””

   2 later decisions quote this exact passage · from the majority
   e.g. United States v. International Business MacHines Corp. · 238 F. Supp. 391 - Dorsey v. State Mutual Life Assurance Co. of Worcester, Mass.

3. ““(c) Paragraph ‘Twentieth’ of section 24 of the Judicial Code is amended by adding at the end thereof the following new paragraph: Concurrent with the Court of Claims, of any suit or proceeding, commenced after the passage of the Revenue Act of 1921, for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected, under the internal-revenue laws, even if the claim exceeds $10,000, if the collector of internal-revenue by whom such tax, penalty, or sum was collected is dead at the time such suit or proceeding is commenced.””

   2 later decisions quote this exact passage · from the majority
   e.g. Bushmiaer v. United States · Exchange Nat. Bank of Shreveport v. United States