Simon v. Commissioner’s Empirical Analysis

Citation profile

6 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “`property subject to the allowance for depreciation' means property that is subject to exhaustion, wear and tear, or obsolescence”

   2 later decisions quote this exact passage · from the majority
   e.g. Roger O'shaughnessy, as Tax Matters Person for Cardinal Ig Company v. Commissioner of Internal Revenue, Roger O'shaughnessy, as Tax Matters Person for Cardinal Ig Company v. Commissioner of Internal Revenue · O'shaughnessy Ig v. Commissioner of Internal Revenue

2. “reasons other than sound accounting practice,” particularly”

   2 later decisions quote this exact passage · from the majority
   e.g. Telecom*USA, Inc. v. United States · 338 U.S. App. D.C. 231 - TelecomUSA, Inc. v. United States

3. “[I]f a taxpayer can prove with reasonable accuracy that an asset used in the trade or business or held for the production of income has a value that wastes over an ascertainable period of time, that asset is depreciable under § 167.... “Whether or not ... a tangible asset, is depreciable for Federal income tax purposes depends upon the determination that the asset is actually exhausting, and that such exhaustion is susceptible of measurement.””

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