Spreckels v. Commissioner’s Empirical Analysis
101 F.2d 721 · 1939
Citation profile
4
cited by 4 later decisions
February 1948
most recently cited
4 federal appellate ·
Relationships
Applies 26 U.S.C. § 161
Relies on Blair v. Commissioner · Freuler v. Helvering · Irwin v. Gavit · Helvering v. Butterworth · Letts v. Commissioner
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 4 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““(a) Application of tax. The taxes imposed by this title [chapter] upon individuals shall apply to the income of estates or of any kind of property held in trust, including— “(1) Income * * * accumulated or held for future distribution under the terms of the will or trust; “(2) Income which is to be distributed currently by the fiduciary to the beneficiaries, * * * “(3) Income received by estates of deceased persons during the period of administration or settlement of the estate; and "(4) Income which, in the discretion of the fiduciary, may be either distributed to the beneficiaries or accumulated. * * * * “§ 162. Net income “The net income of the estate or trust shall be computed in the same manner and on the same basis as in the case of an individual, except that— * * $ * * “(b) There shall be allowed as an additional deduction in computing the net income of the estate or trust the amount of the income of the estate or trust for its taxable year which is to be distributed currently by the fiduciary to the beneficiaries, * * * but the amount so allowed as a deduction shall be included in computing the net income of the beneficiaries whether distributed to them or not. * * “(c) In the case of income * * * which, in the discretion of the fiduciary, may be either distributed to the beneficiary or accumulated, there shall be allowed as an additional deduction * * * the amount of the income of tiie estate or trust for its taxable year, which is properly paid or credited during s”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.