Eustis v. Commissioner’s Empirical Analysis
1934
Citation profile
2 federal appellate · 1 state decisions
How this case has been cited
Cited by 7 later decisions — most recently June 1992
2 federal appellate · 1 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
Relies on Schick v. Commissioner · Hemenway v. Hemenway · Owens v. Commissioner · Allen Gasoline Co. v. Franklin Fire Insurance · Flynn 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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The respondent has urged that, since under the will the income of the trust was to be distributed semiannually, it therefore was income to he distributed currently and under the provisions of section 162 (b) [Revenue Act of 1928, supra] was an allowable deduction to the trust and the amount in controversy was taxable to the petitioner. Giving the provisions of section 162 (b) the construction impliedly contended for by the respondent and applying such construction to the facts in the instant case leads to the conclusion that because the petitioner was a beneficiary of the trust he was taxable on a portion of its income even though he had no present right to receive or demand it, and even though it was not known and could not be determined at the end of his taxable year whether either he or his estate would ever receive it Assuming that the respondent’s contention is correct and that on the day following the close of the petitioner’s taxable year the petitioner had died, the tax on the income in controversy would have been payable by the petitioner’s estate, notwithstanding the fact that neither he during his lifetime nor the estate after his death had received or ever could receive the income. It clearly was not contemplated that a beneficiary would be required to pay a tax on income in the hands of a fiduciary when it was not known and could not be known whether he or his estate would ever receive it or ever be entitled to receive it.”
1 later decision quote this exact passagee.g. Dean v. Commissioner“accumulated in trust for the benefit of * * * unascertained persons or persons with contingent interests * * *.”
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.