Cline v. Commissioner’s Empirical Analysis

Citation profile

18 federal appellate · 1 district · 1 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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “[W]e apply the same standards of review to a Tax Court decision that we apply to district court determinations in a civil bench trial: We review questions of law de novo; we review factual determinations, as well as application of legal principles to those factual determinations, only for clear error.”

   2 later decisions quote this exact passage · from the majority
   e.g. Toushin v. Commissioner · Reynolds v. Commissioner

2. “A finding of fact can be reversed as clearly erroneous only when the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been committed.”

   2 later decisions quote this exact passage · from the majority
   e.g. Pittman v. Commissioner · Toushin v. Commissioner

3. “The golden parachute provisions ... were added to the Internal Revenue Code by the Deficit Reduction Act of 1984 in order to discourage the use of golden parachutes — payments to senior executives of a company in the event of a corporate takeover. Congress found that agreement to make such payments hindered "acquisition activity in the marketplace” by making target corporations less attractive to prospective investors. The prospect of a handsome payment tends to encourage management personnel of the target corporation to favor a proposed takeover, regardless of whether the takeover would be in the best interest of the target corporation's shareholders.”

   1 later decision quote this exact passage · from the majority
   e.g. 66 Fed. Cl. 579 - Yocum v. United States