David I. v. Commissioner’s Empirical Analysis

Citation profile

4 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The travels of the present taxpayer provided him opportunity to sense the trend of life throughout a large segment of the nation. The circumstance that it may have been pleasant or, indeed, have the flavor of a vacation does not negate its nature as an obligation. Surely, the Congress was aware of this pleasurable potential, but nevertheless required it of Foreign Service Officers. Discharge might well have followed a failure to comply with the practice. In obeying, the taxpayer was pursuing his professional employment. Id. at 974-75”

   2 later decisions quote this exact passage
   e.g. Brewin v. Commissioner · Roger C. Brewin and Mary T. Brewin v. Commissioner of Internal Revenue, Kurt H. And Jolanda M. Teil v. Commissioner of Internal Revenue

2. “There is perhaps no phase of Foreign Service administration about which there is more general agreement than that connected with the problem of insuring that Foreign Service personnel should come to the United States as often as possible to renew their knowledge of developments in the United States and their feeling for the American way of life. The new bill, as noted above, provides compulsory home leave after 2 years service abroad as against the present 3 years .... [H.R. Rep.No.2508,' 79th Cong., 2d Sess. 10 (1946).]”

   2 later decisions quote this exact passage
   e.g. Brewin v. Commissioner · Roger C. Brewin and Mary T. Brewin v. Commissioner of Internal Revenue, Kurt H. And Jolanda M. Teil v. Commissioner of Internal Revenue

3. “[0]ne of the prime objectives of the act ... is to insure that officers and employees of the Service shall return more often to the United States to renew touch with the American way of life and so become better representatives of this country abroad. [Ibid p. 139.]”

   2 later decisions quote this exact passage
   e.g. Brewin v. Commissioner · Roger C. Brewin and Mary T. Brewin v. Commissioner of Internal Revenue, Kurt H. And Jolanda M. Teil v. Commissioner of Internal Revenue