United States v. Allen’s Empirical Analysis
293 F.2d 916 · 1961
Citation profile
20 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 40 later decisions — most recently March 2005 · most notably Estate of Christ v. Comm'r (1970), Wheeler v. United States (1997)
20 federal appellate · 1 district · 2 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. § 811
Relies on Blair v. Commissioner · Helvering v. Hallock · Spiegel's Estate v. Commissioner of Internal Revenue · Commissioner v. Wemyss · Cravens 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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It does not seem plausible ... that Congress intended to allow such an easy avoidance of the taxable incidence befalling reserved life estates. This result would allow a taxpayer to reap the benefits of property for his lifetime and, in contemplation of death, sell only the interest entitling him to the income, thereby removing all of the property which he has enjoyed from his gross estate..'.. [I]n a situation like this, Congress meant the estate to include the corpus of the trust or, in its stead, an amount equal in value.”
3 later decisions quote this exact passage“[t]he fact that full and adequate consideration was paid for the transfer of the retained life estate is immaterial. To remove the trust property from inclusion in decedent’s estate there must be full and adequate consideration paid for the interest which would be taxed. That interest is not the right to income for life but the right to the property which was placed in the trust and from which the income is produced.”
1 later decision quote this exact passage“Our narrow question is thus whether the corpus of a reserved life estate is removed, for federal estate tax purposes, from a decedent’s gross estate by. a transfer at the value of such reserved life estate. In other words, must the consideration be paid for the interest transferred, or for the interest which would otherwise be included in the gross estate?”
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.