Estate of Delano T. Starr, Deceased, Mary W. Starr, and Mary W. Starr v. Commissioner of Internal Revenue’s Empirical Analysis
1959
Citation profile
27 federal appellate · 1 state decisions
How this case has been cited
Cited by 45 later decisions — most recently March 1983 · most notably United States v. Cornish (1965), Murphy Logging Co. v. United States (1967)
27 federal appellate · 1 state decisions
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. § 23
Relies on Tennessee Burley Tobacco Growers' Ass'n v. Range · Oesterreich v. Commissioner of Internal Revenue · Western Contracting Corp. v. Commissioner · Robinson v. Elliot
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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Yesterday’s equities in personal property seem to have become today’s leases. This has been generated not a little by the circumstance that one who leases as a lessee usually has less trouble with the federal tax collector. At least taxpayers think so.””
1 later decision quote this exact passage · from the majority“[W]here the foreordained practical effect of the rent is to produce title eventually, the rental agreement can be treated as a sale.”
1 later decision quote this exact passage · from the majority“taxpayer has not taken or is not taking title or in which he has no equity.”
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.