Greiner v. Lewellyn’s Empirical Analysis

Citation profile

29 federal appellate · 18 district · 20 state decisions

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

1. “* * * A State may impose a legacy tax on a bequest to the United States, United States v. Perkins, 163 U. S. 625 , or on a bequest which consists wholly of United States bonds, Plummer v. Coler, 178 U. S. 115 ; Orr v. Gilman, 183 U. S. 278 . Likewise the Federal Government may impose a succession tax upon a bequest to a municipal corporation of a State, Snyder v. Bettman, 190 U. S. 249 , or may, in determining the amount for which the estate tax is assessable, under the Act of 1916, include sums required to be paid to a state as inheritance tax, for the estate tax is the antithesis of a direct tax, New York Trust Co. v. Eisner, supra. Municipal bonds of a State stand in this respect in no different position from money payable to it. The transfer upon death is taxable, whatsoever the character of the property transferred and to whomsoever the transfer is made. It follows that in determining the amount of decedent’s net estate municipal bonds were properly included.”

   3 later decisions quote this exact passage · from the majority
   e.g. Willcuts v. Bunn · Bankers Trust Co. v. Commissioner