Heidel v. Commissioner’s Empirical Analysis

Citation profile

2 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. “While we might assume that petitioner’s performance as a football defensive halfback at Ole Miss in 1963 and 1964 was responsible, in substantial part at least, for the contract he was offered by the Cardinals, it is not clear that petitioner’s activities at Ole Miss qualify as “work” within the meaning of section 1303(c) (2) (B), see Wilson v. United States, 322 F. Supp. 830 (D. Kan. 1971), or, even if it does, that the bonus was attributable to that work. Conversely, it would also be reasonable to assume that the Cardinals were not paying petitioner $50,-000 for football he had played at Ole Miss, but were paying him either to sign their contract rather than sign the New York Jets contract or to play football for the Cardinals in the future. In any event the burden was on petitioner to prove that the bonus was attributable to work performed by petitioner during 1963 and 1964, and in the absence of evidence indicating that the payment was for something other than stated in the contract, and in the light of our doubts that petitioner’s activities at Ole Miss were the type of work intended to be covered by subparagraph (B), we conclude that petitioner has failed to carry his burden of proof, and we must decide this issue against petitioner. [Fn. omitted.]”

   1 later decision quote this exact passage · from the majority
   e.g. Frost v. Commissioner

2. “hardly qualified, "within the letter and spirit of the Congressional grant,” as indicated by the committee reports, as an individual to whom relief was sought to be granted by the income-averaging provisions. Throughout the base period years he was a full-time student, was not a regular member of the labor force, and the value of the scholarship which he claims as support furnished to himself was not subject to U.S. taxes. [ 56 T.C. at 103 .]”

   1 later decision quote this exact passage · from the majority
   e.g. Baldwin v. Commissioner

3. “(g)enerally, individuals age 25 or over will be eligible for averaging so long as they have been out of school for at least four years.”

   1 later decision quote this exact passage · from the majority
   e.g. Sharvy v. Commissioner