Kent 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(e) Law Applicable to Computations. — In determining the amount of any net operating loss carryback or carryover to any taxable year, the necessary computations involving any other taxable year shall be made under the law applicable to such other taxable year. The preceding sentence shall apply with respect to all taxable years, whether they begin before, on, or after January 1,1954.”

   2 later decisions quote this exact passage
   e.g. Humacid Co. v. Commissioner · American Bank & Trust Co. v. United States

2. “The portion of such loss which shall be carried to each of the other 6 taxable years shall be the excess, if any, of the amount of such loss over the sum of the taxable income for each of the prior taxable years to which such loss may be carried.”

   1 later decision quote this exact passage
   e.g. United States v. Whitney Land Co.

3. “[T]he term `net operating loss' means (for any taxable year ending after December 31, 1953) the excess of the deductions allowed by this chapter over the gross income.”

   1 later decision quote this exact passage
   e.g. United States v. Whitney Land Co.