United States v. Wells’s Empirical Analysis
283 U.S. 102 · 1931
Citation profile
283 federal appellate · 109 district · 107 state decisions
How this case has been cited
Cited by 1,003 later decisions (54 by the Supreme Court) — most recently February 2017 · most notably Commissioner of Internal Revenue v. Culbertson (1949), Heiner v. Donnan (1932)
283 federal appellate · 109 district · 107 state decisions — followed in 17 states
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 Botany Worsted Mills v. United States · Nichols v. Coolidge · Milliken v. United States · Bromley v. McCaughn
Cited together with Allen v. Trust Co. · Milliken v. United States · Nichols v. Coolidge · Reinecke v. Northern Trust Co. · Heiner v. Donnan
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 1,003 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“to reach substitutes for testamentary dispositions and thus to prevent the evasion of the estate tax.”
72 later decisions quote this exact passage · from the majority““(a) General rule. The value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth) * * * in contemplation of his death. “(b) Application of general rule. If the decedent within a period of 3 years ending with the date of his death (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth) transferred an interest in property * * * such transfer * * * shall, unless shown to the contrary, be deemed to have been made in contemplation of death within the meaning of this section * * * but no such transfer * * made before such 3-year period shall be treated as having been made in contemplation of death.” Under section 2035 as amended by the Tax Reform Act of 1976, Pub.L. 9AA55, 90 Stat. 1520 , 1848, gifts within 3 years of death are taxable to the estate without regard to the state of mind of the donor.”
5 later decisions quote this exact passage · from the majority“by deed, grant, bargain, sale or gift, made in contemplation of death of *Page 14 the grantor, vendor, or donor, or intended to take effect in possession or enjoyment at or after such death.”
5 later decisions 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.