BMC Software, Inc. v. Commissioner’s Empirical Analysis

Citation profile

5 federal appellate · 1 district · 1 state decisions

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

1. “If the language is plain and unambiguous, it must be given effect.”

   2 later decisions quote this exact passage · from the majority
   e.g. Christiana Trust, of Wilmington Sav. Fund Soc'y, FSB v. Riddle · Miner v. Johns

2. “had been included. See dissenting op. p. 51. That is not at all what the Court of Appeals said or implied, and this selective quotation is taken out of context. The Court of Appeals rejected the Commissioner's submission that the parties had agreed to backdate the accounts receivable for all Federal tax purposes, concluding instead that the parties had agreed to backdate the accounts receivable only for”

   1 later decision quote this exact passage · from the majority
   e.g. 147 T.C. No. 15 - Analog Devices v. Comm'r

3. “[t]he text of * * * [section] 965(b)(3) specifically requires that the determination of the final amount of indebtedness be made 'as of the close of the taxable year for which the [section 965 ] election * * * is in effect.'”

   1 later decision quote this exact passage · from the majority
   e.g. 147 T.C. No. 15 - Analog Devices v. Comm'r