McCain v. Commissioner’s Empirical Analysis

Citation profile

2 federal appellate · 2 district ·

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

1. “rights and legal status of United States Government agencies and employees operating in the Republic of Panama pursuant to this Article, shall be governed by the Agreement in Implementation of this Article.”

   2 later decisions quote this exact passage
   e.g. Coplin v. United States · Rust v. Commissioner

2. “Paragraph 2 exempts United States citizen employees and dependents from the imposition by Panama of taxes on income received as a result of their work with the Commission and on the income derived from sources outside Panama. Such persons are subject, however, to Panamanian taxation of any income derived from sources outside [sic] Panama, other than their employment with the United States Government. [Emphasis added.]”

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

3. “Taken on its face, the "any taxes” language may be read literally to grant the broad tax exemption urged by petitioner. When paragraph 2 is read in context with paragraphs 1 and 3 of article XV, however,' we find that the language of paragraph 2 does not clearly grant this exemption.”

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