Helvering v. Clifford’s Empirical Analysis

Citation profile

1,272 federal appellate · 56 district · 58 state decisions

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 2,676 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““In substance his control over the corpus was in all essential respects the same after the trust was created, as before. * * * We have at best a temporary reallocation of income within an intimate family group. Since the income remains in the family and since the husband retains control over the investment, he has rather complete assurance that the trust will not effect any substantial change in his economic position. It is hard to imagine that respondent felt himself the poorer after this trust had been executed or, if he did, that it had any rational foundation in fact””

   28 later decisions quote this exact passage · from the majority
   e.g. Helvering v. Horst · Hormel v. Helvering

2. “to use the full measure of its taxing power.”

   19 later decisions quote this exact passage · from the majority
   e.g. Commissioner of Internal Revenue v. J Kowalski · HCSC-Laundry v. United States

3. “'Technical considerations, niceties of the law of trusts or conveyances, or the legal paraphernalia which inventive genius may construct' must not frustrate an examination of the facts in the light of economic realities”

   9 later decisions quote this exact passage · from the majority
   e.g. Sun First National Bank v. United States · Simon M. Lazarus v. Commissioner of Internal Revenue, Mina Lazarus v. Commissioner of Internal Revenue, Simon M. And Mina Lazarus v. Commissioner of Internal Revenue