Commissioner v. Rust's Estate’s Empirical Analysis
116 F.2d 636 · 1940
Citation profile
3 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 10 later decisions (2 by the Supreme Court) — most recently July 1965
3 federal appellate · 1 district · 2 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
Relationships
Relies on New Colonial Ice Co. v. Helvering · Liverpool Steam Co v. Insurance Co of North America · Lyon v. Alley · Shotwell v. Moore · Tumulty v. District of Columbia
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“only the person owning the property at that time [i.e., when the tax lien attaches] is subjected to the burden which the law imposes; and only the person who has been thus subjected to the burden of the tax is entitled to a deduction for paying it. Payment by a subsequent purchaser is not the discharge of a burden which the law has placed upon him, but is actually as well as theoretically a payment of purchase price; for, after the lien attaches and the taxing authority becomes pro tanto an owner of an interest in the property, payment of the tax by a purchaser is nothing but a part of the payment for unencumbered title.”
2 later decisions quote this exact passage · from the majority“to enforce the liens acquired aforesaid shall not release the property from any tax whatsoever that may be due the District.”
1 later decision quote this exact passage · from the majority“A lien for taxes on real estate is a creature of statute, and attaches only when the legislature prescribes.”
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.