Commissioner v. Southwest Exploration Co.’s Empirical Analysis

Citation profile

454 federal appellate · 12 district · 9 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 789 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “is designed to permit a recoupment of the owner's capital investment in the minerals so that when the minerals are exhausted, the owner's capital is unimpaired.”

   15 later decisions quote this exact passage · from the majority
   e.g. Commissioner v. Estate of Donnell · Reich v. Commissioner

2. ““Annual depletion deductions are allowed to the owner of an economic interest in mineral deposits * * * An economic interest is possessed in every case in which the taxpayer has acquired by investment any interest in mineral in place * * * and secures, by any form of legal relationship, income derived from the extraction of the mineral * * * to which he must look for a return of his capital. But a person who has no capital investment in the mineral deposit * * * does not possess an economic interest merely because through a contractual relation he possesses a mere economic or pecuniary advantage derived from production. * * * ””

   14 later decisions quote this exact passage · from the majority
   e.g. Whitmer v. Commissioner · Filtrol Corp. v. United States

3. “the tax law deals in economic realities, not legal abstractions * * *.”

   8 later decisions quote this exact passage · from the majority
   e.g. PPL Corp. v. Comm'r of Internal Revenue · Bosque Disposal Sys., LLC v. Parker Cnty. Appraisal Dist.