Schuster v. Commissioner’s Empirical Analysis
1962
Citation profile
51 federal appellate · 1 district · 14 state decisions
How this case has been cited
Cited by 191 later decisions (1 by the Supreme Court) — most recently May 2023 · most notably Dixon v. Unied States (1965), Kimberly-Clark Corp. v. Dubno (1987)
51 federal appellate · 1 district · 14 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 Phillips v. Commissioner · Automobile Club of Mich. v. Commissioner · Phillips v. Commissioner · Commissioner v. Stern · Helvering v. City Bank Farmers Trust Co.
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 191 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“against the Government with utmost caution and restraint”
36 later decisions quote this exact passage · from the majority“in those rare instances where the equitable interest of the party asserting estoppel is 'compelling' and the loss which it would sustain is 'unwarrantable' and 'unconscionable'.”
7 later decisions quote this exact passage · from the majority““We conclude that the transferee’s liability for estate tax deficiencies, under federal law, is essentially a primary, not a secondary, obligation. Section 827(b) [a predecessor statute to § 6324] specifically imposes some limitations on the liability of such a transferee, for it requires that a deficiency be due from the estate, and that his liability therefor is limited to the value of the estate corpus which he received. But no other limitations were imposed, and there is nothing to suggest that others were intended. Therefore, it seems axiomatic that the transferee’s liability for an estate tax deficiency is not conditioned on the Commissioner’s remedies against the estate, except as the statute provides otherwise, and is in the nature of a direct and primary obligation independent of the obligation of the estate.” (p. 315) See also United States v. Prince, 120 F.Supp. 563 (S.D.N.Y.1954) and United States v. Fisher, 57 F.Supp. 410 (E.D.Mich.1944); both of which seem to imply that assessment must be made against the transferee where the government does not proceed on an equitable or “trust fund” theory.”
2 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.