Helvering v. Hallock’s Empirical Analysis
309 U.S. 106 · 1940
Citation profile
467 federal appellate · 67 district · 288 state decisions
How this case has been cited
Cited by 1,468 later decisions (166 by the Supreme Court) — most recently July 2025 · most notably Monroe v. Pape (1961), Seminole Tribe of Florida v. Florida (1996)
467 federal appellate · 67 district · 288 state decisions — followed in 37 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
reviewedCommissioner v. Hallock (from Sixth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 811
Relies on Lyeth v. Hoey · Sanford's Estate v. Commissioner of Internal Revenue · Reinecke v. Northern Trust Co. · Hassett v. Welch
Cited together with May v. Heiner · Helvering v. St. Louis Union Trust Co. · Klein v. United States · Becker v. St. Louis Union Trust Co. · Spiegel's Estate v. Commissioner of Internal Revenue
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 1,468 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“stare decisis is a principle of policy and not a mechanical formula of adherence to the latest decision, however recent and questionable, when such adherence involves collision with a prior doctrine more embracing in its scope, intrinsically sounder, and verified by experience.”
32 later decisions quote this exact passage · from the majority“[W]e walk on quicksand when we try to find in the absence of corrective legislation a controlling legal principle”
17 later decisions quote this exact passage · from the majority““§ 811. Gross Estate The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated, except real property situated outside of the United States— * * * (c) Transfers in contemplation of, or taking effect at, death (1) General Rule. To the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise— (A) in contemplation of bis death; or (B) under which he has retained for his life * * * (i) the possession or enjoyment of, or the right to the income from, the property * * * (ii) Transfers for insufficient consideration.”
13 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.