Umbach v. Commissioner’s Empirical Analysis

Citation profile

1 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 116 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “the amount received by such individual from sources within a foreign country * * * which constitute earned income attributable to services performed by such individual”

   4 later decisions quote this exact passage · from the majority
   e.g. Rogers v. Comm'r · Clark v. Comm'r

2. “included Johnston Island. 8 Section 1272(a) of the TRA 1986 amended old section 931 to exclude from income, in the case of an individual who is a bona fide resident of a specified possession during the entire taxable year, gross income derived from sources within any such specified possession. Section 931 , as amended by section 1272(a) of the TRA 1986 , defines the term”

   2 later decisions quote this exact passage · from the majority
   e.g. Smith v. Comm'r · Qunell v. Comm'r

3. “The Treasury's relaxed approach to amending its regulations to track Code changes is well documented. * * * The absence of any amendment * * * is more likely a reflection of the Treasury's inattention than any affirmative intention on its part to say anything at all.”

   1 later decision quote this exact passage · from the majority
   e.g. Smith v. Comm'r