Granquist v. Harvey’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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “the number of taxpayer’s exemptions was known, the tax rate was fixed, and the tax paid was proven * * *. Also produced were Ms Oregon state returns for the same years * * *. * * * sfc * * ⅜ It is thus apparent that there was sufficient evidence as to what the returns contained. True, it was secondary evidence, hut we know of no rule excluding the use of such evidence to prove the contents of a destroyed or lost return just as in the case of any other document where the original is unavailable. ⅜ ⅜ *”

   1 later decision quote this exact passage · from the majority
   e.g. Estate of Clarke v. Commissioner

2. ““ * * * for the simple reason that the returns were not in evidence, nor was there any evidence as to what information the returns contained. The Commissioner showed only that the Collector’s records indicated that the petitioner husband had paid certain amounts in taxes for those years. Nowhere in the record is there any evidence of the gross or net income reported, nor of the credits or deductions either claimed by the taxpayer or allowable to him.””

   1 later decision quote this exact passage · from the majority
   e.g. Putman v. United States