Schiff v. United States’s Empirical Analysis

Citation profile

7 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “a showing that the parties to the lease at the time of execution realistically contemplated that the lease's term would not extend beyond 50 percent of the leased property's useful life,”

   3 later decisions quote this exact passage · from the majority
   e.g. Hauptli v. Commissioner · August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal Revenue

2. “(3) NONCORPORATE LESSORS. — A credit shall be allowed by section 38 to a person which is not a corporation with respect to property of which such person is the lessor only if— (B) the term of the lease (taking into account options to renew) is less than 50 percent of the useful life of the property, and for the period consisting of the first 12 months after the date on which the property is transferred to the lessee the sum of the deductions with respect to such property which are allowable to the lessor solely by reason of section 162 (other than rents and reimbursed amounts with respect to such property) exceeds 15 percent of the rental income produced by such property.”

   2 later decisions quote this exact passage · from the majority
   e.g. Hauptli v. Commissioner · August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal Revenue

3. “inappropriate because it shifts the burden of proof to the government, * * * ignoring the thrust of Rule 142(a), Tax Court Rules of Practice and Procedure * * * (taxpayer bears burden of proof in protesting deficiency assessed by Commissioner)”

   1 later decision quote this exact passage · from the majority
   e.g. Glickman v. Commissioner