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← 23 TC 254 - Stone v. Commissioner

Stone v. Commissioner’s Empirical Analysis

1954

Citation profile

12
cited by 12 later decisions
1
cited 1 times by the Supreme Court
1
states following
August 2014
most recently cited

1 federal appellate · 1 state decisions

How this case has been cited

Cited by 12 later decisions (1 by the Supreme Court) — most recently August 2014

1 federal appellate · 1 state decisions

701954196019701980199020002010decided

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. § 117

Relies on Old Colony Trust Co. v. Commissioner · Bogardus v. Commissioner · Robertson v. United States · Stelmack v. Glen Alden Coal Co. · United States v. Robertson

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

  1. “We have found that the fellowship payment to the petitioner was a gift. On this issue the controlling factor is the intent of the payor. Bogardus v. Commissioner [of Internal Revenue], 302 U.S. 34 [ 58 S.Ct. 61 , 82 L.Ed. 32 ] (1937). It is obvious that the foundation intended it as a gift. The object of the foundation is to aid scholars, scientists, and artists in the prosecution of their labors. The donor of the capital fund stated that the income was to be used to provide opportunities for men and women to carry on advanced study. The secretary of the foundation testified that the fellowship awards were intended as gifts.”
    2 later decisions quote this exact passage
  2. “on the basis of the petitioner's qualifications to do the work required by his project, which project was approved by the foundation with the expectation of results consistent with the petitioner's qualifications”
    1 later decision quote this exact passage
  3. “In providing funds to qualified persons to carry out their own projects of creative work or self-advancement the foundation is carrying out the desires of its founders to give others educational opportunities”
    1 later decision quote this exact passage

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.