Burnet v. Wells’s Empirical Analysis
289 U.S. 670 · 1933
Citation profile
332 federal appellate · 24 district · 25 state decisions
How this case has been cited
Cited by 707 later decisions (63 by the Supreme Court) — most recently June 2024 · most notably Aetna Life Ins Co of Hartford Conn v. Haworth (1937), Helvering v. Clifford (1940)
332 federal appellate · 24 district · 25 state decisions — followed in 11 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.
Appellate journey
reviewedWells v. Commissioner (from Eighth Circuit Court of Appeals)
Relationships
Relies on Lucas v. Earl · Old Colony Trust Co. v. Commissioner · Brushaber v. Union Pacific Railroad · Corliss v. Bowers · Reinecke v. Northern Trust Co.
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 707 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But taxation is not so much concerned with the refinements of title as it is with actual command over the property taxed — the actual benefit for which the tax is paid.””
9 later decisions quote this exact passage · from the majority““§ 167. Income for benefit of grantor. “(a) Where any part of the income of a trust — ■ “(1) is, or in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income may be, held or accumulated for future distribution to the grantor; or “(2) may, in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income, be distributed to the grantor; or “(3) is, or in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income may be, applied to the payment of premiums upon policies of insurance on the life of the grantor (* * *);”
2 later decisions quote this exact passage · from the majority““Income permanently applied by the act of the taxpayer to the maintenance of contracts of insurance made in his name for the support of his dependents is income used for his benefit in such a sense and to such a degree that there is nothing arbitrary or tyrannical in taxing it as his. >}c $s * * sj< “The relation between the parties, the tendency of the transfer to give relief from obligations that are recognized as binding by normal men and women, will be facts to be considered.””
2 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.