Sanford's Estate v. Commissioner of Internal Revenue’s Empirical Analysis
308 U.S. 39 · 1939
Citation profile
473 federal appellate · 33 district · 74 state decisions
How this case has been cited
Cited by 1,071 later decisions (75 by the Supreme Court) — most recently February 2025 · most notably Michigan v. Long (1983), Higgins v. Smith (1940)
473 federal appellate · 33 district · 74 state decisions — followed in 15 states
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
reviewedSanford's Estate v. Commissioner (from Third Circuit Court of Appeals)
Relationships
Relies on Corliss v. Bowers · Brewster v. Gage · Morrissey v. Commissioner · Reinecke v. Northern Trust Co.
Cited together with Burnet v. Guggenheim · Smith v. Shaughnessy · Commissioner v. Wemyss · Rasquin v. Humphreys · Merrill v. Fahs
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 1,071 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“' "taxation is not so much concerned with the refinements of title as it is with the actual command over the property taxed.”
15 later decisions quote this exact passage · from the majority“are not bound to accept as controlling, stipulations as to questions of law.”
8 later decisions quote this exact passage · from the majority“[tjhere is nothing in the language of the statute, and our attention has not been directed to anything in its legislative history to suggest that Congress had any purpose to tax gifts before the donor had fully parted with his interest in the property given, or that the test of the completeness of the taxed gift was to be any different from that to be applied in determining whether the donor has retained an interest such that it becomes subject to the estate tax upon its extinguishment at death.... The two [taxes] are in pari materia and must be construed together.”
7 later decisions 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.