Coulter 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * ¶¾6 fallacy, however, of the petitioner’s position is in the idea that the wash sale disallowance connotes an identity in the shares sold and those purchased within the preceding 80 days. The wash sale statute is not concerned with the identity of the shares sold, hut only provides categorically that the deduction shall be disallowed if any substantially identical property is acquired within SO days. For the purpose of the wash sale provision, therefore, it is only necessary that the Commissioner should disallow so much of tlie loss as is proportionately applicable to 200 shares. In determining the measure of the loss sustained on the sale of the 500 shares on December 18, the first in, first out rule is no less applicable because part of the loss is precluded from deduction under the wash sale statute.”

   1 later decision quote this exact passage
   e.g. Heinz v. Commissioner