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

1. “There was never any charge made by petitioner for any information or counsel he gave or any service he rendered the Bruners or either of them, nor was there any promise made or any assurance, express or implied, given him that he would be paid or compensated for what he did for them. The 216 shares of stock issued to petitioner were an absolute gift, which was made or prompted by the feeling of moral obligation and high sense of appreciation on John W. Bruner’s part, for the kind and valuable services rendered him and his son by a genuine friend. The fact that petitioner’s friendship, suggestions, and services were beneficial to the Bruners does not convert what was clearly a tona fide gift to petitioner into compensation, for such services so as to make the amount of the gift income, taxable under the statute.”

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