Heiner v. Mellon’s Empirical Analysis

Citation profile

51 federal appellate · 3 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 110 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The tax is thus imposed upon the partner’s proportionate share of the net income of the partnership, and the fact that it may not be currently distributable, whether by agreement of the parties or by operation of law, is not material.””

   5 later decisions quote this exact passage · from the majority
   e.g. Hulbert v. Commissioner · Burke v. Comm'r

2. ““When a partner retires from a partnership, or it is dissolved, he realizes a gain or loss measured by the difference between the price received for his interest and the cost to him or (if acquired prior thereto) the fair market value as of March 1, 1913, of his interest in the partnership, including in such cost or value the amount of his share in any undistributed partnership net income earned since February 28, 1913, on which’income tax has been paid.”

   1 later decision quote this exact passage · from the majority
   e.g. Heiner v. Mellon

3. ““Losses suffered by a taxpayer in a later-year may be deducted from profits, if any,, earned by him in that later year; but the-tax on a year’s income may not be withheld because losses may thereafter occur.”'”

   1 later decision quote this exact passage · from the majority
   e.g. Anderson v. Bowers