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← 28 BTA 543 - Wright v. Commissioner

Wright v. Commissioner’s Empirical Analysis

1933

Citation profile

17
cited by 17 later decisions
September 1979
most recently cited

1 district ·

How this case has been cited

Cited by 17 later decisions — most recently September 1979

1 district ·

8019331940195019601970decided

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 Keller v. Commissioner · Wire Wheel Corp. v. Commissioner · Evans v. Commissioner · Kaufmann v. Commissioner · Graham v. Commissioner

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

  1. “We have repeatedly held that a transfer of assets does not necessarily result in transferee liability, and indeed does not result in such liability unless the taxpayer is thereby rendered insolvent and unable to pay the tax. Samuel Keller, 21 B. T. A. 84; aff'd., 59 Fed. (2d) 499; Charles Havard, 25 B. T. A. 1161; M. K. Graham, 26 B. T. A. 301. See also United States v. Armstrong, 26 Fed. (2d) 227. So long as the original taxpayer is in existence and solvent, collection of the tax may not be enforced from a transferee. The remedy against the transferee may be pursued only when there is no available remedy against the transferor. Wire Wheel Corporation of America, 16 B. T. A. 737; aff'd., 46 Fed. (2d) 1013. There was no liability on the part of these petitioners as transferees until the assets of the decedent’s estate had been distributed to them and the estate left without means to pay its tax.”
    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.