Goodman v. Granger’s Empirical Analysis
243 F.2d 264 · 1957
Citation profile
16 federal appellate · 3 district ·
How this case has been cited
Cited by 30 later decisions — most recently June 1998 · most notably United States v. Land (1962), Worthen v. United States (1961)
16 federal appellate · 3 district ·
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. § 811
Relies on Knowlton v. Moore · New York Trust Co. v. Eisner · Young Men's Christian Ass'n of Columbus Ohio v. Davis · Edwards v. Slocum · United States Trust Co. v. Helvering
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“our approach in the instant case, although the language used by the Tax Court was perhaps something less than fortunate.”
2 later decisions quote this exact passage · from the majority““Since death is the propelling force for the imposition of the tax, it is death which determines the interests to be includible in the gross estate. Interests which terminate on or before death are not a proper subject of the tax. Assets may be acquired or disposed of before death, possibilities of the loss of an asset may become actualities or may disappear. Upon the same principle underlying the inclusion of interest in a decedent’s gross estate, valuation of an interest is neither logically made nor feasibly administered until death has occurred. The taxpayer’s theory of valuing property before death disregards the fact that generally the estate tax is neither concerned with changes in property interests nor values prior to death. The tax is measured by the value of assets transferred by reason of death, the critical value being that which is determined as of the time of death.” Goodman v. Granger, 3 Cir., 243 F.2d 264, 268, 269 (1957).”
1 later decision quote this exact passage · from the majority“There can not be a decedent, till death has occurred. A decedent’s estate is not transferred either by his will or by intestacy, till death has occurred. Moreover, the value of the decedent’s estate is expressly stated to be “the value at the time of his death”. Ibid. § 811 [§ 2031(a)], And the.decedent’s interest in the property taxable is to be such interest “at the time of his death”. Ibid. § 811(a) [§ 2033].”
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.