Paxton v. Commissioner’s Empirical Analysis

Citation profile

3 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “individual whose efforts created such property,”

   2 later decisions quote this exact passage
   e.g. Ransburg Corp. v. Commissioner · Busse v. Commissioner

2. “Sales or exchanges of patents. Section 483 does not apply to any payments made pursuant to a transfer described in section 1235(a) (relating to sale or exchange of patents). The preceding sentence does not apply to transfers which are not described in section 1235(a) but which receive capital gain treatment under another section of the Code.”

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

3. “[T]he term 'total unstated interest' means, with respect to a contract for the sale or exchange of property, an amount equal to the excess of- "(1) the sum of the payments * * * which are due under the contract, over "(2) the sum of the present values of such payments and the present values of any interest payments due under the contract.”

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