Webb 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “since March 1, 1913. (Emphasis supplied.) Thus, the statute itself seemed to place all taxpayers, regardless of their accounting method, on an accrual method for purposes of calculating their earnings and profits. Furthermore, the court, in that case, cited regulations of the Commissioner which provided that”

   2 later decisions quote this exact passage · from the majority
   e.g. Arenstein v. Commissioner · Mazzocchi Bus Co. v. Commissioner

2. “in ascertaining whether or not a distribution was made out of earnings or profits of the taxable year there should first be set aside a proper reserve for the payment of accrued income and war profits and excess profits taxes.”

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

3. “assumes that there must be some correlation between general corporate law concepts of capital and earning surplus and the Federal income tax concepts of capital and earnings and profits, an assumption which is not correct.”

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