Tucson v. Commissioner’s Empirical Analysis

Citation profile

2 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 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “any obligation which is issued as part of an issue all or a major portion of the proceeds of which are reasonably expected to be used directly or indirectly— (A) to acquire securities ... or obligations ... which may be reasonably expected at the time of issuance of such issue, to produce a yield over the term of the issue which is materially higher ... than the yield on obligations of such issue, or (B) to replace funds which were used directly or indirectly to acquire securities or obligations described in subparagraph (A). 9”

   1 later decision quote this exact passage
   e.g. City of Tucson v. Commissioner

2. “in every borrowing t may be said generally that a replacement of funds occurs; namely, the substitution of borrowed funds for moneys reasonably anticipated to be earned or collected in the future to repay the debt.”

   1 later decision quote this exact passage
   e.g. City of Tucson v. Commissioner