Paparo 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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “This paragraph [par. 2 of sec. 302(b)] shall not apply to any redemption made pursuant to a plan the purpose or effect of which is a series of redemptions resulting in a distribution which (in the aggregate) is not substantially disproportionate with respect to the shareholder.”

   1 later decision quote this exact passage
   e.g. Glacier State Electric Supply Co. v. Commissioner

2. “[w]hile [the Paparos] apparently intended that subsequent public offerings be made in futuro, there was no promise to sell any particular amount of stock between the underwriter and [the Paparos] at any particular price.”

   1 later decision quote this exact passage
   e.g. Merrill Lynch & Co. v. Commissioner