Schottenstein v. Commissioner’s Empirical Analysis

Citation profile

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

1. “"If the payments required under * * * the separation agreement effected a property division or satisfied [the wife’s] property rights, they would be neither includable in her gross income under section 71(a) nor deductible by [the husband] under section 215, since they would be capital in nature. [Emphasis added.]””

   1 later decision quote this exact passage
   e.g. Beard v. Commissioner

2. “amounts includible under section 71 in the gross income of his wife, payment of which is made within the husband's taxable year.”

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

3. “in settlement of some property interest of the wife.”

   1 later decision quote this exact passage
   e.g. Hoover v. Commissioner