Haley v. Commissioner’s Empirical Analysis

Citation profile

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

1. “but the regulations provide that amounts representing”

   2 later decisions quote this exact passage
   e.g. Woodfin v. Commissioner · Willie v. Commissioner

2. ““The petitioner also attempts to support an exclusion for 75 percent of her educational grant under the theory that the grantor was the united States, not the State of Oregon. Her argument is that, as she had no employment relationship with the Federal Government, the grant, to the extent funded by Federal moneys under a 75 percent matching program, could not be in consideration of her ‘past, present, or future services’ to the Federal Government. Petitioner’s argument must fail as her agreement was not with the Federal Government and as she did not receive funds from the Department of Health, Education, and Welfare or any other Federal Agency. The Federal government was not the grantor. Cf. Norman R. Williamsen, Jr., 32 T.C. 154 (1950). The grantor of the funds was the State Commission, and the funds were distributed from the general funds of the State of Oregon.””

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

3. “bargained-for payments, given only as a 'quo' in return for the quid of services rendered - whether past, present or future - should not be excludable from income as 'scholarship' funds.”

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