Thomas v. Perkins’s Empirical Analysis

Citation profile

277 federal appellate · 3 district · 12 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 513 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The language of the statute is broad enough to provide, at least, for every case in which the taxpayer has acquired, by investment, any interest in the oil” (or other mineral, presumably) “in place, and secures, by any form of legal relationship, income derived from the extraction of the oil, to which he must look for a return of his capital.” Palmer v. Bender, 1933, 287 U.S. 551 , at page 557, 53 S.Ct. 225 , at page 226, 77 L.Ed. 489 .”

   2 later decisions quote this exact passage · from the majority
   e.g. Stallard v. United States · United States v. Morgan

2. “The provisions for payment to assignors in oil only, the absence of any obligation of the assignee to pay in oil or in money, and the failure of assignors to take any security by way of lien or otherwise unmistakably show that they intended to withhold from the operation of the grant one-fourth of the oil to be produced and saved up to an amount sufficient when sold to yield [the purchase price].”

   2 later decisions quote this exact passage · from the majority
   e.g. Holbrook v. Commissioner · Anderson v. Commissioner

3. “payable out of oil only * * * and said oil payment does not constitute and shall not be a personal obligation of the assignee * * *.”

   2 later decisions quote this exact passage · from the majority
   e.g. Finley W. Holbrook and Faith Holbrook v. Commissioner of Internal Revenue · Finley W. Holbrook and Faith Holbrook v. Commissioner of Internal Revenue