Kaufman v. Shulman’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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “paragraph (g)(6) appears designed in case of extinguishment both (1) to prevent taxpayers from reaping a windfall if the property is destroyed or condemned and they get the proceeds from insurance or condemnation and (2) to assure that the donee organization can use its proportionate share of the proceeds to advance the cause of historic preservation elsewhere. [Fn. ref. omitted.]”

   4 later decisions quote this exact passage · from the majority
   e.g. PBBM-Rose Hill, Ltd. v. Comm'r of Internal Revenue · Irby v. Comm'r

2. “But whether the valuation was overstated, grossly or otherwise, is a factual question different from whether the formal procedural requirements were met, either strictly or under the 'substantial compliance' doctrine which may forgive minor discrepancies.”

   4 later decisions quote this exact passage · from the majority
   e.g. Kaufman v. Comm'r · Costello v. Comm'r

3. “requires that "when a change in conditions gives rise to the extinguishment of a perpetual conservation restriction [by judicial proceeding], the donee organization, on a subsequent sale, exchange, or involuntary conversion of the subject property, must be entitled to a portion of the proceeds at least equal to that proportionate value of the perpetual conservation restriction, unless state law provides that the donor is entitled to the full proceeds from the conversion.””

   3 later decisions quote this exact passage · from the majority
   e.g. Kaufman v. Commissioner · PBBM-Rose Hill, Ltd. v. Comm'r of Internal Revenue