Emery 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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Of material bearing on the issue, furthermore, is the city’s inferable purpose in adopting the refunding plan and the method chosen to carry it into effect. The outstanding bonds bore a higher rate of interest than the current money market demanded; it would have been to the city’s advantage to call the old bonds at the earliest call date, and to issue new bonds at lower rates. In effect it accomplished this result in an anticipatory manner by paying the old rate on the new bonds until the old bonds’ first call date and the lower rate thereafter. The refunding bonds, so viewed, are thus clothed with the character of a new obligation, having different terms and conditions. * * * [Emphasis added.]”

   1 later decision quote this exact passage · from the majority
   e.g. West Missouri Power Co. v. Commissioner

2. “a thing really different from what he theretofore had.”

   1 later decision quote this exact passage · from the majority
   e.g. Federal Nat'l Mortg. Asso. v. Commissioner