Galt v. Commissioner’s Empirical Analysis
1954
Citation profile
24 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 59 later decisions — most recently October 2009 · most notably Alvary v. United States (1962), Godfrey v. Commissioner of Internal Revenue (1964)
24 federal appellate · 1 district · 1 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
Applies 26 U.S.C. § 1000
Relies on Commissioner v. Sunnen · Helvering v. Horst · Lucas v. Earl · Blair v. Commissioner · Sanford's Estate v. Commissioner of Internal Revenue
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The tree which produced the fruit in the instant case was the property, owned by petitioner after the execution of the lease as it had been before. The lease merely evidenced the manner in which the fruit from the tree should be distributed. Of course, by execution of the lease, petitioner’s property rights were diminished to the extent that they were acquired by the lessee but no interest in the property or in the lease was transferred to the sons other than the right to receive income, the fruit from the tree.” 216 F.2d at 46 .”
1 later decision quote this exact passage“ * * * it is supported by the principal announced in many cases, which in substance is that one who retains property from which income is produced is obligated to account therefor even though he has assigned it, thereby divesting himself of all control, and even though it is actually received by the assignee and not by him.”
1 later decision quote this exact passage“One vested with the right to receive income did not escape the tax by any kind of anticipatory arrangement, however skillfully devised, by which he procures payment of it to another, since, by the exercise of his power to command the income, he enjoys the benefit of the income on which the tax is laid.”
1 later decision quote this exact passagee.g. Winters v. Dallman
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.