Denman v. Slayton’s Empirical Analysis

Citation profile

35 federal appellate · 6 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 142 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Sec. 23. Deductions from Gross Income. In computing net income there shall be allowed as deductions: * * * “(n) Charitable and other contributions. — In the case of an individual, contributions or gifts made within the taxable year to or for the use of: * * * “(2) any corporation, or trust, or community chest, fund, or foundation, organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private shareholder or individual; * * * to an amount which in all the above cases combined does not exceed 15 per centum of the taxpayer’s net income as computed without the benefit of this subsection. * * a "■ “Sec. 101. Capital Net Gains and Losses. “(a) Tax in case of capital net gain.— In the ease of any taxpayer, other than a corporation, who for any taxable year derives a capital net gain (as hereinafter defined in this section), there shall, at the election of the taxpayer, be levied, collected, and paid, in lieu of all other taxes imposed by this title, a tax determined as follows: a partial tax shall first be computed" upon the basis of the ordinary net income at the rates and in the manner as if this section had not been enacted and the total tax shall be this amount plus 12% per centum of the capital net gain. “(b) Tax in case of capital net loss.— In the case of any taxpayer, other than a corporation, who fo”

   7 later decisions quote this exact passage · from the majority
   e.g. Hunt-Wesson, Inc. v. Franchise Tax Board of California · Phipps v. Bowers

2. “The manifest purpose of the exception in paragraph 2, § 214(a), [Revenue Act of 1921, 42 Stat. 238 , 239, the predecessor of section 265] was to prevent the escape from taxation of income properly subject thereto by the purchase of exempt securities with borrowed money.”

   3 later decisions quote this exact passage · from the majority
   e.g. Phipps v. United States · Jacobson v. Commissioner

3. “While guaranteed exemptions must be strictly observed, this obligation is not inconsistent with reasonable classification designed to subject all to the payment of their just share of a burden fairly imposed.”

   3 later decisions quote this exact passage · from the majority
   e.g. 1994 Conn. Super. Ct. 12133 - D.A. Pincus Co., Inc. v. Meehan, No. 377269 (Nov. 29, 1994) · First National Bank of Atlanta v. Bartow County Board of Tax Assessors