Page v. Skinner’s Empirical Analysis

Citation profile

8 federal appellate · 7 district · 1 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The estate taxes, under the act of 1918, were due and payable one year from the date of decedent’s death. There was, however, contained in the later act a saving clause, which is designated as section 1400 (b) of sueh act, which provides as follows: ‘The parts of the Revenue Act of 1918, which are repealed by this act shall (unless otherwise specifically provided in this act) remain in force for the assessment and collection of all taxes which have accrued under the Revenue Act of 1918 at the time such parts cease to be in effect. * * * ’ 42 Stat. 320 , 321. “The construction placed upon the provisions of this saving clause will determine the sole question presented upon the demurrer in this ease. If, as contended by the plaintiffs, the above saving clause is to be construed so as to relieve all persons from the payment of any estate taxes, who died within one year immediately preceding the 23d day of November, 1921, the date of the approval of the Revenue Act of 1921, then the demurrer must be overruled and the complaint held to state a cause of action. “The saving clause in the act of 1921 applies to ‘all taxes which have accrued under the Revenue Act of 1918,’ and it is the contention of the plaintiffs that the word ‘accrued,’ as used in that clause, means that such taxes must have been due and payable at the time of the taking effect of the act of 1921, that is, on November 23d of that year. Since the taxes paid by plaintiffs were not due and payable until the expiration”

   2 later decisions quote this exact passage · from the majority
   e.g. United States v. Ayer · O'Brien v. Sturgess

2. ““Neither are we in doubt as to the meaning of the word ‘accrued,’ found in sub-paragraph (b); as contended by counsel amici curiae, who appear for another estate in like conditions, that it is equivalent to arising under and refers to all taxes/ including estate taxes, arising under the prior acts, and is not a restriction to those that were due and payable prior to February 25th.””

   1 later decision quote this exact passage · from the majority
   e.g. Ewbank v. United States