Helvering v. City Bank Farmers Trust Co.’s Empirical Analysis

Citation profile

170 federal appellate · 38 district · 8 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 431 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “are unnecessary or inappropriate to the proposed end, are unreasonably harsh or oppressive, when viewed in the light of the expected benefit, or arbitrarily ignore recognized rights to enjoy or to convey individual property.”

   5 later decisions quote this exact passage · from the majority
   e.g. Schuster v. Commissioner · Wemyss v. Commissioner

2. ““Sec. 302. The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated— * * * “(d) To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power in contemplation of his death, except in case of a bona, fide sale for an adequate and full consideration in money or money’s worth. * * *””

   3 later decisions quote this exact passage · from the majority
   e.g. Fair v. Commissioner · Gallery v. Commissioner

3. ““We are not at liberty to construe language so plain as to need no construction, or to refer to committee reports where there can be no doubt of the meaning of the words used.””

   2 later decisions quote this exact passage · from the majority
   e.g. Pugh v. United States · Hatchett v. Government of Guam