Joachim v. Commissioner’s Empirical Analysis

Citation profile

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

1. ““Because all of the interest of the decedent in this fund was vested in the united States at the time of her death, there would, except for the provisions of section 36 of the Trading with the Enemy Act, be nothing of value with respect to it to include in her gross estate for estate tax purposes. That section gives the United States the right, for tax purposes, to disregard the vesting of the interest of the decedent in the Custodian and authorizes the Custodian to pay any Eederal tax, including an estate tax, ‘to the same extent as though the property or interest had not been vested in or transferred to him.’ The question arises, therefore, to what extent would the interest of the decedent in the $168,361.80 have been subject to estate tax if it had not been vested in the Custodian at the time of her death.””

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

2. “The following items shall not, for the purpose of this subchapter, be deemed property within the United 'States: ******* (b) Bank Deposits. — Any moneys deposited with any person carrying on the banking business, by or for a nonresident not a citizen of the United States who was not engaged in business in the United States at the time of his death.”

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