Pacific Nat Co v. Welch’s Empirical Analysis

Citation profile

125 federal appellate · 22 district · 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 332 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““[cjhange from one method to the other ... would require recomputation and readjustment of tax liability for subsequent years and impose burdensome uncertainties upon the administration of the revenue laws.... There is nothing to suggest that Congress intended to permit a taxpayer, after expiration of the time within which return is to be made, to have his tax liability computed and settled according to the other method.””

   22 later decisions quote this exact passage · from the majority
   e.g. Jacobs v. Commissioner · Lord v. United States

2. ““Installment method “(a) Dealers in personal property. — Under regulations prescribed by the Secretary or his delegate, a person who regularly sells or otherwise disposes of personal property on the installment plan may return as income therefrom in any taxable year that proportion of the installment payments actually received in that year which the gross profit, realized or to be realized when payment is completed, bears to the total contract price. “(b) Sales of realty and casual sales of personalty.— “(1) General rule. — Income from “(A) a sale or other disposition of real property, or “(B) a casual sale or other casual disposition of personal property (other than property of a kind which would properly be included in the inventory of the taxpayer if on hand at the close of the taxable year) for a price exceeding $1,000, may (under regulations prescribed by the Secretary or his delegate) be returned on the basis and in the manner prescribed in subsection (a).””

   2 later decisions quote this exact passage · from the majority
   e.g. Morrison v. Commissioner · 225 F. Supp. 965 - Stouffer v. United States

3. ““(b) SALES OF REAL PROPERTY AND CASUAL SALES OF PERSONAL PROPERTY. (1) A taxpayer * * * who makes a casual sale or other casual disposition of personal property, and who elects to report the income therefrom on the installment method must set forth in his income tax return (or in a statement attached thereto) for the year of the sale or other disposition the computation of the gross profit on the sale or other disposition under the installment method. * * *””

   1 later decision quote this exact passage · from the majority
   e.g. 225 F. Supp. 965 - Stouffer v. United States