Want v. Commissioner’s Empirical Analysis

Citation profile

12 federal appellate · 1 district · 3 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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “a distribution of funds [from the estate] that is not, strictly speaking, the payment of a debt.”

   3 later decisions quote this exact passage · from the majority
   e.g. Allen v. Commissioner · Estate of Frost v. Commissioner

2. ““However, it has long been held that a fiduciary is liable only if it had notice of the claim of the United States before making the distribution. [Citing a case] Clearly petitioner would be personally liable, whether under the statute [Section 192] or under § 1026(b), as regards any distribution made out of trust assets after May 25, 1951, when the notice of deficiency was served. And she may also be so liable as to distributions made before then if at the time she had actual notice of the government’s intention to hold the trust liable as transferee for the gift tax and penalties on the 1945 gifts. * * * ” (Page 783)”

   1 later decision quote this exact passage · from the majority
   e.g. 257 F. Supp. 931 - United States v. Vibradamp Corporation

3. “Every executor, administrator, or assignee, or other person, who pays, in whole or in part, any debt due by the person or estate for whom or for which he acts before he satisfies and pays the debts due to the United States from such person or estate, shall become answerable in his own person and estate to the extent of such payments for the debts so due to the United States, or for so much thereof as may remain due and unpaid.”

   1 later decision quote this exact passage · from the majority
   e.g. Estate of Want v. Commissioner