Gray v. Commissioner’s Empirical Analysis

Citation profile

5 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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “As of September 21, 1962, the distribution in liquidation was complete. Through his agents, including Cameron and Dabne, Gray obtained complete dominion and control of all the assets of Yarg; at this time composed of cash and the Omark 1960 preferred stock.”

   3 later decisions quote this exact passage · from the majority
   e.g. Gray v. Commissioner · John D. Gray v. Commissioner Of Internal Revenue

2. “This letter will be our undertaking that we will . . . purchase all of the issued shares of a company known as Yarg Ltd. for cash in an amount equal to the net book value less 41/2 percent of undistributed income. . . . "Under the terms of an escrow agreement to be drawn, it is understood that we will not be bound to complete the purchase until the Company's assets are shown to be cash and that its only liabilities will be capital and surplus. . . .”

   2 later decisions quote this exact passage
   e.g. John D. Gray v. Commissioner Of Internal Revenue · Gray v. Commissioner

3. “Once the fog of Cameron and Dabne is blown away by the fresh air of economic reality the substance of the transactions is clearly visible. On September 26, 1962, the petitioners, collectively, had $1,681,400 (Canadian dollars) in cash . . . . The question now to be answered is how did this cash and these assets come to rest with petitioners.”

   2 later decisions quote this exact passage · from the majority
   e.g. John D. Gray v. Commissioner Of Internal Revenue · Gray v. Commissioner