Commissioner of Internal Revenue v. Estate of Ellie G. Canfield, Deceased, Karl B. Smith, Jr., Administrator, C.T.A.’s Empirical Analysis
1962
Citation profile
14 federal appellate · 1 district · 1 state decisions
How this case has been cited
Cited by 32 later decisions — most recently April 2020 · most notably Nassau Lens Co., Inc. v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Harry Pildes and Sarah Pildes (1962), Mull v. Colt Co. (1962)
14 federal appellate · 1 district · 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
Applies 26 U.S.C. § 2036 · 26 U.S.C. § 811
Relies on Corliss v. Bowers · Sanford's Estate v. Commissioner of Internal Revenue · Reinecke v. Northern Trust Co. · Hassett v. Welch · May v. Heiner
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““What result we would reach in a case involving a trust revocable by the settlor acting alone * * * is a question we need not and do not decide.””
2 later decisions quote this exact passage · from the majority““In the joint resolution of March 3, 1931, Congress created a new estate tax rule with rcsx>oct to transfers after March 3. It left unchanged the rule in effect for transfers before that date. It is the opinion of your committee that the old rule should have been continued in effect with respect to such transfers until changed by legislation. Since the rule has been changed by the Supreme Court in the Church opinion, your committee believes that the Congress should act to restore the estate tax law to what it was prior to the Church opinion*””
1 later decision quote this exact passage · from the majority““ * * * The power was exercisable both during his lifetime and by testamentary instrument. The decedent relinquished this power in 1944. The Court held, nevertheless, that the ‘transfer’ was made in 1930 upon execution of the deed of trust. It noted that a contrary ruling would attribute a different meaning to ‘transfer’ than it had in other parts of the same statute and that the May v. Heiner line of cases was principally concerned with placing formal legal title beyond the settlor’s unilateral control. * * * ” (306 F.2d p. 7).”
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.