Bowers v. Lawyers Mortgage Co.’s Empirical Analysis

Citation profile

70 federal appellate · 15 district · 7 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 149 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““While name, charter powers, and subjection to state insurance laws have significance as to the business which a corporation is authorized and intends to carry on, the character of the business actually done in the tax years determines whether it was taxable as an insurance company. United States v. Phellis, 257 U.S. 156, 168 , 42 S.Ct. 63 , 66 L.Ed. 180 . Weiss v. Stearn, 265 U.S. 242, 254 , 44 S.Ct. 490 , 68 L.Ed. 1001 , 33 A.L.R. 520 .””

   2 later decisions quote this exact passage · from the majority
   e.g. Oklahoma Ben. Life Ass'n v. Jones · Allied Fidelity Corp. v. Commissioner of Internal Revenue

2. “The term “gross income” means the combined gross amount, earned during the taxable year, from investment income and from underwriting income as provided in this subdivision, computed on the basis of the underwriting and investment exhibit of the annual statement approved by the National Convention of Insurance Commissioners.”

   1 later decision quote this exact passage · from the majority
   e.g. Dallas Title & Guaranty Co. v. Commissioner

3. ““Insurance companies other than life or mutual “(a) Imposition of tax. In lieu of the tax imposed by section 13 of this title, there shall be levied, collected, and paid for each taxable year upon the net income of every insurance company (other than a life or mutual insurance company) a tax as follows:” etc.”

   1 later decision quote this exact passage · from the majority
   e.g. 21 F. Supp. 754 - Empire Title & Guarantee Co. v. United States