M. E. Blatt Co. v. United States’s Empirical Analysis

Citation profile

86 federal appellate · 9 district · 11 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 169 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “It may be assumed that, subject to tbe lease, lessor became owner of tbe improvements at tbe time they were made. But it bad no right to use or dispose of tbem during tbe term. Mere acquisition of that sort did not amount to contemporaneous realization of gain witbin tbe meaning of tbe statute.”

   3 later decisions quote this exact passage · from the majority
   e.g. Helvering v. Lent · Tobias v. Commissioner

2. ““Even when required, improvements by lessee will not be deemed rent unless intention that they shall be is plainly disclosed.””

   3 later decisions quote this exact passage · from the majority
   e.g. Brown v. Commissioner · Isidore Brown and Gladys J. Brown v. Commissioner of Internal Revenue

3. “Granting that the improvements increased the value of the building, that enhancement is not realized income of lessor. 7 So far as concerns taxable income, the value of the improvements is not distinguishable from excess, if any there may be, of value over cost of improvements made by lessor. Each was an addition to capital; not income within the meaning of the statute. 8 Treasury Regulations can add nothing to income as defined by Congress. 9”

   2 later decisions quote this exact passage · from the majority
   e.g. Cleveland Trust Co. v. Commissioner · United States v. Mississippi Chemical Co.