Lucas v. Kansas City Structural Steel Co.’s Empirical Analysis

Citation profile

204 federal appellate · 21 district · 8 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 473 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Section 22(c) provides two tests to which each inventory must conform: “(1) It must conform as nearly as may be to the best accounting practice in the trade or business, and “(2) It must clearly reflect the income. “It follows, therefore, that inventory rules cannot be uniform but must give effect to trade customs which come within the scope of the best accounting practice in the particular trade or business. In order clearly to reflect income, the inventory practice of a taxpayer should be consistent from' year to year, and greater weight is to be given to consistency than to any particular method of inventorying or basis of valuation so long as the method or basis used is substantially in accord with these regulations. An inventory that can be used under the best accounting practice in a balance sheet showing the financial position of the taxpayer can, as a general rule, be regarded as clearly reflecting his income. “The bases of valuation most commonly used by business concerns and which meet the requirements of section 22(c) are (a) cost and (b) cost or market, whichever is lower. * * *»”

   6 later decisions quote this exact passage · from the majority
   e.g. Finance & Guaranty Co. v. Commissioner of Internal Revenue · Adair v. Commissioner

2. “heavy burden of proving that the Commissioner's action was plainly arbitrary.”

   6 later decisions quote this exact passage · from the majority
   e.g. Thor Power Tool Company v. Commissioner of Internal Revenue · Hurley v. United States

3. “is to assign to each period its profits and losses.”

   3 later decisions quote this exact passage · from the majority
   e.g. Reynolds Cattle Co. v. Commissioner · Jacob Strauch v. United States of America, Alex Strauch v. United States of America, Harry Benjamin Sher v. United States