Wells v. Commissioner’s Empirical Analysis

Citation profile

1 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Where any part of the income of a trust is or may be applied to the payment of premiums upon policies of insurance on the life of the grantor (except policies of insurance irrevocably payable for the purposes and in the manner specified in paragraph (10) of subdivision (a) of section 214), such part of the income of the trust shall be included in computing the net income of the grantor.”

   1 later decision quote this exact passage
   e.g. Du Pont v. Commissioner

2. “Trusts have been used to evade taxes by means of provisions allowing the distribution of the income to the grantor or its use for his benefit. The purpose of this subdivision of the bill is to stop this evasion.”

   1 later decision quote this exact passage
   e.g. Burnet v. Wells

3. “to prevent the evasion of taxes by means of estates and trusts.”

   1 later decision quote this exact passage
   e.g. Pillsbury v. Commissioner