Reinecke v. Spalding’s Empirical Analysis

Citation profile

254 federal appellate · 42 district · 10 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 515 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““(1) This does not accurately státe our understanding of the issue. It was necessary for the taxpayer to show the illegality of the exactions. ‘The burden of establishing that fact rested upon it, in order to show that it was entitled to the deduction which the Commissioner had disallowed, and that the additional tax was to that extent illegally assessed.' Botany [Worsted] Mills v. United States, 278 U.S. 282, 289, 290 , 49 S.Ct. 129, 132 , 73 L.Ed. 379 ; United States v. Anderson, 269 U.S. 422, 443 , 46 S.Ct. 131 , 70 L.Ed. 347 . The real point is whether respondent established her claim for refund by adequate evidence. And we think she did not.””

   1 later decision quote this exact passage · from the majority
   e.g. McGill v. Oklahoma Tax Commission

2. “* * * Manifestly, the fair market value of this interest in 1913 was much less than 25 cents per ton of the estimated contents of the mines, but respondent introduced no evidence which tended to show such value.”

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

3. “That in compiiting net income there shall be allowed as deductions: (1) All the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business.”

   1 later decision quote this exact passage · from the majority
   e.g. Brown v. Helvering