Frankel v. Commissioner’s Empirical Analysis

Citation profile

2 federal appellate ·

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 6 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * The provision for augmenting the payments of net income was contingent upon the combined annual net income payable from the trust and the income from her own property being less than $20,000 — a contingency which has never arisen. It was also contingent upon request being made by her that her income be so augmented. As we view it. the provision did not affect the gift of net income to petitioner nor change her status from an income beneficiary to that of a legatee. ,At most it was a contingent grant of an uncertain sum having none of the attributes of an annuity payable at all events.”

   2 later decisions quote this exact passage
   e.g. Coleman Trust v. Commissioner · Northern Trust Co. v. Commissioner

2. “* * * in such installments and at such times as my said wife may request, provided, however, and it is my will that in any event my wife shall have and enjoy during each year of her natural life, a net income which together with the net annual income of her own property, shall be not less than Twenty Thousand Dollars ($20,000.00) per annum and should the net income in any one year to which my said wife may be entitled to receive from my Trust Estate, when added to the net annual income of her own property, be less than Twenty Thousand Dollars ($20,000.00). then the net income for that year shall be augmented, if my wife shall so request, by adding thereto from the principal of any said Trust Estate such amount or amounts as may be necessary to produce the sum of Twenty Thousand Dollars ($20,000.00), which shall be paid to my beloved wife as above provided.”

   1 later decision quote this exact passage
   e.g. Coleman Trust v. Commissioner