Hamill v. Commissioner’s Empirical Analysis

Citation profile

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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(c) Inventories. — Whenever in the opinion of the Commissioner the use of inventories is necessary in order clearly to determine the income of any taxpayer, inventories shall be taken by such taxpayer upon such basis as the Commissioner, with the approval of the Secretary, may prescribe as conforming as nearly as may be to the best accounting practice in the trade or business and as most clearly reflecting the income.”

   3 later decisions quote this exact passage
   e.g. Vaughan v. Commissioner · Securities-Allied Corp. v. Commissioner

2. “* * * For the purpose of this rule a dealer in securities is a merchant of securities, whether an individual, partnership, or corporation, with an established place of business, regularly engaged in the purchase of securities and their resale to customers; that is, one who as a merchant buys securities and sells them to customers with a view to the gains and profits that may be derived therefrom.”

   3 later decisions quote this exact passage
   e.g. Fried v. Commissioner · Vaughan v. Commissioner

3. “undoubtedly heavier than that of overthrowing a purely factual determination upon which the ultimate determination must stand.”

   1 later decision quote this exact passage
   e.g. BRENDLE v. COMMISSIONER