PPL Corp. v. Commissioner’s Empirical Analysis

Citation profile

1 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 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Say that the tax rate on the hypothetical extraction tax is 20%. It is true that a 20% tax on 105% of receipts is mathematically equivalent to a 21% tax on 100% of receipts, the latter of which would satisfy the gross receipts requirement. PPL proposes that we make the same move here, increasing the tax rate from 23% to 51.75% so that there is no multiple of receipts in the tax base. But if the regulation allowed us to do that, the example would be a nullity. Any tax on a multiple of receipts or profits could satisfy the gross receipts requirement, because we could reduce the starting point of its tax base to 100% of gross receipts by imagining a higher tax rate.”

   1 later decision quote this exact passage · from the majority
   e.g. PPL Corp. v. Comm'r of Internal Revenue

2. “[i]n the case of ... a domestic corporation, the amount of any income, war profits, and excess profits taxes paid or accrued during the taxable year to any foreign country or to any possession of the United States”

   1 later decision quote this exact passage · from the majority
   e.g. PPL Corp. v. Comm'r of Internal Revenue

3. “average annual profit during its 'initial period' ... times 9, the assumed price-to-earnings ratio.”

   1 later decision quote this exact passage · from the majority
   e.g. PPL Corp. v. Comm'r of Internal Revenue