Johnston 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““To accept that theory we must conclude that Congress provided for the separate computation of partnership net income, but intended that the total so reached would be discarded and the individual items of gain or loss, income or deduction, would then be separated and each brought forward into the returns of the several partners, in the proportionate amounts of these partners’ individual interests in profits, and there combined, in each case, with nonpartnership income and deductions, to arrive at the partners’ net taxable income.””

   1 later decision quote this exact passage
   e.g. Klingenstein v. United States

2. “no part of any loss disallowed to a partnership as a deduction by section 23 (r) shall be allowed as a deduction to a member of such partnership in computing net income.”

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