Hall v. Commissioner’s Empirical Analysis

Citation profile

6 federal appellate ·

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

1. “The term 'controlled' includes any kind of control, direct or indirect, whether legally enforceable, and however exercisable or exercised. It is the reality of the control which is decisive, not its form or the mode of its exercise. A presumption of control arises if income or deductions have been arbitrarily shifted.”

   3 later decisions quote this exact passage
   e.g. B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue, B. Forman Company, Inc. v. Commissioner of Internal Revenue, McCurdy & Company, Inc. v. Commissioner of Internal Revenue · Jesse E. Hall, Sr., and Rhoda O. Hall v. Commissioner of Internal Revenue

2. “in any case of two or more organizations, trades, or businesses (whether or not incorporated, whether or not organized in the United States, and whether or not affiliated) owned or controlled directly or indirectly by the same interests * * *.”

   1 later decision quote this exact passage
   e.g. Jesse E. Hall, Sr., and Rhoda O. Hall v. Commissioner of Internal Revenue

3. “However, regardless of the question of the ownership of the [Venezuela] Spring Co. stock, we think the record is abundantly clear that Hall controlled [Venezuela] Spring Co. during the taxable years.”

   1 later decision quote this exact passage
   e.g. Jesse E. Hall, Sr., and Rhoda O. Hall v. Commissioner of Internal Revenue