Commissioner v. Pierce’s Empirical Analysis
146 F.2d 388 · 1944
Citation profile
5 federal appellate · 3 state decisions
How this case has been cited
Cited by 13 later decisions — most recently May 1968
5 federal appellate · 3 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.
Relationships
Relies on New Colonial Ice Co. v. Helvering · Lyeth v. Hoey · Willcuts v. Bunn · Helvering v. Butterworth · Phoenix Fire Marine Ins Co of Memphis v. State of Tennessee City of Memphis
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.
““Existing law exempts the proceeds of life insurance from tax where they are received under a life-insurance contract and are paid by reason of the death of the insured. Where the life-insurance contract contains an option to have the proceeds paid at a date later than death, either in a lump sum or in installments, the total payments continue to be exempt, even though a substantial portion of such payments may include interest earned after the death of the insured. On the other hand, where the proceeds are retained by the insurer under a specific agreement to pay interest (for example, where proceeds are left with the insurer under an agreement to pay the interest to the beneficiary for life and to pay the principal to a second beneficiary on the death of the first), the interest payments must be included in gross income. Similarly, where the beneficiary and the insurer, by a supplemental agreement instead of an option contained in the policy, provide for payment in installments, the installments are not considered to be paid by reason of death and as a result the interest becomes taxable.” (H.Rep. No. 1337, 83d Cong., 2d Sess., p. 14, U.S.Code Cong, and Adm.News 1954, p. 4038. In considering Section 101 of the Internal Revenue Code of 1954 (the successor to Section 22(b) (1)).”
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.