Heiner v. Tindle’s Empirical Analysis

Citation profile

81 federal appellate · 9 district · 11 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 224 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The loss here has resulted from the sale of property not used for residential purposes by the taxpayer, and the transaction entered into for profit, and resulting in the loss was not the purchase of the property but its appropriation to rental purposes. The article of the regulations by its terms has no application to a loss so incurred.””

   2 later decisions quote this exact passage · from the majority
   e.g. Larkin v. Gage · Bullock v. Commissioner

2. ““But the words ‘any transaction’ as used in sub-sectioii (a) 5, are not a technical phrase or one of art. They must therefore be taken in their usual sense and, so taken, they are, we think, broad enough to embrace at least any action or business operation, such as that with which we are now concerned, by which property previously acquired is devoted exclusively to the production of taxable income.””

   1 later decision quote this exact passage · from the majority
   e.g. Gaunt v. Glenn

3. ““Art. 141. Losses. — * * • A loss in the sale of residential property is not deductible unless the property was purchased or constructed by the taxpayer with a view to its subseqeunt sale for pecuniary profit.””

   1 later decision quote this exact passage · from the majority
   e.g. Larkin v. Gage