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← 27 TC 601 - Perkins v. Commissioner

Perkins v. Commissioner’s Empirical Analysis

1956

Citation profile

16
cited by 16 later decisions
June 1997
most recently cited

3 federal appellate ·

How this case has been cited

Cited by 16 later decisions — most recently June 1997

3 federal appellate ·

6019561960197019801990decided

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

Relies on Gregory v. Helvering · United States v. Pelzer · Commissioner of Internal Revenue v. Disston · Fondren v. Commissioner · Ryerson v. United States

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

  1. “Had the power to demand income or principal been limited to the beneficiaries or their duly appointed guardians, respondent’s position, at least as to all gifts other than the two aforementioned, might well be tenable; there would have been at the time such gifts were made no person who could make an effective demand for immediate use, possession, and enjoyment by the beneficiaries. Stifel v. Commissioner, 197 F. 2d 107 (C.A. 2), affirming 17 T.C. 647 . * * *”
    2 later decisions quote this exact passage
  2. “regardless of the petitioners’ motives, or why they did what they in fact did, the legal rights in question were created by the trust instruments and could at any time thereafter be exercised. Petitioners having done what they purported to do, their tax-saving motive is irrelevant. [Perkins v. Commissioner, 27 T.C. at 606 .]”
    1 later decision quote this exact passage
  3. “The issue as to whether a gift is of a present or future interest is not one of the time of vesting, but rather whether there is any substantial barrier to the present use, possession, or enjoyment by the donee.”
    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.