Murphy v. Internal Revenue Service’s Empirical Analysis
460 F.3d 79 · 2006
Citation profile
2 federal appellate · 1 district ·
Relationships
Applies 26 U.S.C. § 1012 · 26 U.S.C. § 104 · 26 U.S.C. § 61 (Payment-in-Kind Tax Treatment Act of 1983) · 26 U.S.C. § 7421 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 2201 · 5 U.S.C. § 703
Relies on Anderson v. Liberty Lobby, Inc. · M'Culloch v. State of Maryland · Helvering v. Clifford · Commissioner of Internal Revenue v. Glenshaw Glass Company · United States v. Morrison
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.
“Without affirming that the human body is in a technical sense the “capital” invested in an accident policy, in a broad, natural sense the proceeds of the policy do but substitute, so far as they go, capital which is the source of future periodical income. They merely take the place of capital in human ability which was destroyed by the accident. They are therefore “capital” as distinguished from “income” receipts.”
1 later decision quote this exact passage“award is not income and section 104(a)(2) is therefore unconstitutional insofar as it would make the award taxable as income.”
1 later decision quote this exact passagee.g. Suder v. Comm'r“personal physical injuries or physical sickness”
1 later decision quote this exact passagee.g. Suder v. Comm'r
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.