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

1. “We hold that the income from petitioner’s business from and after July 29, 1927, through 1939 should be apportioned between the capital invested and his services; that the apportionment to capital should he an amount equal to 7 percent of such capital, and that the remainder of the business income should be apportioned to petitioner’s services in conducting such business. The latter is community income and the former is separate and community income in the proportions that the capital comprises separate and community property.”

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

2. “the management, activities, and skill of petitioner constituted the principal contribution to the earnings of the business.”

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