Mason v. Routzahn’s Empirical Analysis

Citation profile

52 federal appellate · 13 district · 1 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 130 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““ The Solicitor General concedes that Edwards v. Douglas does not so decide; that the case is authority only for the proposition that a pro rata share of the entire year’s earnings may be treated as approximating the actual earnings for the fraction of the year prior to the payment of the dividend in the absence of circumstances showing that there were no earnings actually accumulated during the fractional period; that the amount actually available for payment of dividends out of the current year’s earnings prior to the date of payment may always be shown; that such had been the practice of the Treasury Department from the time the revenue act of 1917 took effect until the date of the Court of Appeals’ decision; and that this rule was embodied in its regulations. “We see no good reason for disturbing the long-settled practice of the Treasury Department. Its contemporary interpretation is consistent with the language of the act, and its practice was, in susbtanee, embodied in the revenue act of 1918, February 24, 1919, c. 18, sec. 201 (e), 40 Stat. 1057 , 1060. We conclude that the Circuit Court of Appeals placed an erroneous construction on sec. 31 (b).””

   2 later decisions quote this exact passage · from the majority
   e.g. Moody v. Commissioner · Horst v. United States