Sullivan 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “SEC. 402(a). Taxability of Beneficiary of Exempt Trust.— * * * * sic * * (2) Capital gains treatment for portion of lump sum distribution. — In the case of an employee trust described in section 401(a), which is exempt from tax under section 501(a), so much of the total taxable amount (as defined in subparagraph D of subsection (e)(4)) of a lump sum distribution as is equal to the product of such total taxable amount multiplied by a fraction— (A) the numerator of which is the number of calendar years of active participation by the employee in such plan before January 1, 1974, and (B) the denominator of which is the number of calendar years of active participation by the employee in such plan, shall be treated as a gain from the sale or exchange of a capital asset held for more than 1 year. * * *”

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

2. “with respect to the income of every person”

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