Miller v. Commissioner’s Empirical Analysis

Citation profile

14 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “for the sake of,” "by reason of,” or "because of,”

   4 later decisions quote this exact passage
   e.g. Rickel v. Commissioner · Frank E. & Mildred E. Rickel v. Commissioner of Internal Revenue

2. “Section 104 does not distinguish between physical and nonphysical injuries, and we see no sound reason to construe the statute in such a way as to not afford the same tax treatment to recoveries for all types of 'personal' injury regardless of consequence.”

   2 later decisions quote this exact passage
   e.g. Rickel v. Commissioner · Pistillo v. Commissioner

3. “the plain meaning of the broad statutory language simply does not permit a distinction between punitive and compensatory damages.... Thus, we read 'any damages' to mean 'all' damages, including punitive damages.”

   2 later decisions quote this exact passage
   e.g. Ernest and Mary C. Horton v. Commissioner of Internal Revenue · Horton v. Commissioner