Helvering v. Helmholz’s Empirical Analysis
296 U.S. 93 · 1935
Citation profile
94 federal appellate · 24 district · 10 state decisions
How this case has been cited
Cited by 226 later decisions (11 by the Supreme Court) — most recently June 1997 · most notably Sanford's Estate v. Commissioner of Internal Revenue (1939), Helvering v. City Bank Farmers Trust Co. (1935)
94 federal appellate · 24 district · 10 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.
Appellate journey
reviewedHelvering v. Helmholz (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Reinecke v. Northern Trust Co. · Nichols v. Coolidge · Helvering v. City Bank Farmers Trust Co. · Helvering v. Helmholz
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 226 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““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, except real property situated outside of the United States— * * * * * * “(c) Transfers m contemplation of, or taking effect at death. To the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, in contemplation of or intended to take effect in possession or enjoyment at or after his death, or of which he has at any time made a transfer, by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons wbo shall possess or enjoy the property or the income therefrom; except in case of a bona fide sale for an adequate and full consideration in money or money’s worth. * * * “(d) Revocable transfers “(1) Transfers after June 22, 19$6. 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), by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exe”
2 later decisions quote this exact passage · from the majority“argument overlooks the essential difference between a power to revoke, alter, or amend, and a condition which the law imposes”
1 later decision 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.