Lynch v. Alworth-Stephens Co.’s Empirical Analysis

Citation profile

256 federal appellate · 33 district · 18 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 575 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “the plain, obvious and rational meaning of a statute is always to be preferred to any curious, narrow, hidden sense that nothing but the exigency of a hard case and the ingenuity and study of an acute and powerful intellect would discover.”

   24 later decisions quote this exact passage · from the majority
   e.g. Helvering v. Falk · Deputy v. du Pont

2. ““Upon the foregoing facts and under these statutory provisions, the question presented for consideration is whether the relation of respondent to the mines which were-the source of its income, was such that it was-entitled to deduct from the gross amount of such income a reasonable amount for exhaustion or depletion. Upon the part of the-petitioner the contention is that the leases-do not convey to the lessee the ore bodies, but are contracts of rental conferring only the right to use and occupy the premises and mine the ore, which, so long as it remains in the ground, is the property of the fee owner. It is therefore insisted that by the extraction of the ore, only the property of the fee-owner is depleted and such owner alone is entitled to an allowance therefor. On the other hand, respondent contends that under the leases the lessee, as well as the lessor,. owns a valuable property interest in the mines and by the terms of the statute each is entitled to deduct from gross income a reasonable allowance for depletion, the lessee for exhaustion of the leasehold interest and the lessor for exhaustion of the fee interest as lessened by the interest of the lessee, such deduction to be allowed according to the value of the interest of each in the property, the entire allowance, however, not to exceed the total market value in the mine of the product thereof mined and sold during the taxable year. “It is, of course, true that the leases here under review did not convey title to th”

   10 later decisions quote this exact passage · from the majority
   e.g. Herold v. Commissioner · Bakertown Coal Co. v. United States

3. “(m) Depletion. In the case of mines, oil and gas wells, other natural deposits, and timber, a reasonable allowance for depletion and for depreciation of improvements, according to the peculiar conditions in each case; such reasonable allowance in all cases to be made under rules and regulations to be prescribed by the Commissioner, with the approval of the Secretary. In any case in which it is ascertained as a result of operations or of development work that the recoverable units are greater or less than the prior estimate thereof, then such prior estimate (but not the basis for depletion) shall be revised and the allowance under this subsection for subsequent taxable years shall be based upon such revised estimate. In the case of leases the deductions shall be equitably apportioned between the lessor and lessee. In the case of property held by one person for life with remainder to another person, the deduction shall be computed as if the life tenant were the absolute owner of the property and shall be allowed to the life tenant. In the case of property held in trust the allowable deduction shall be apportioned between the income beneficiaries and the trustee in accordance with the pertinent provisions of the instrument creating the trust, or, in the absence of such provisions, on the basis of the trust income allocable to each.”

   1 later decision quote this exact passage · from the majority
   e.g. Turkey Run Fuels, Inc. v. United States