Crawford 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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “a sensible construction of section 183(e)(4) is that it modifies section 6501(a) with regard to a section 183 activity for which an election under section 183(e)(1) has been made.”

   1 later decision quote this exact passage
   e.g. Robert E. Wadlow and Connie v. Wadlow v. Commissioner

2. “would be effective only with regard to assessments arising from deficiencies attributable to the section 183 activity.”

   1 later decision quote this exact passage
   e.g. Robert E. Wadlow and Connie v. Wadlow v. Commissioner

3. “the statutory period for the assessment of any deficiency”

   1 later decision quote this exact passage
   e.g. Robert E. Wadlow and Connie v. Wadlow v. Commissioner