Guggenheim v. Rasquin’s Empirical Analysis
312 U.S. 254 · 1941
Citation profile
133 federal appellate · 13 district · 12 state decisions
How this case has been cited
Cited by 318 later decisions (9 by the Supreme Court) — most recently February 2016 · most notably United States v. Cartwright (1973), Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal Revenue (1963)
133 federal appellate · 13 district · 12 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.
Appellate journey
reviewedGuggenheim v. Rasquin (from Second Circuit Court of Appeals)
Relationships
Relies on Chase Nat Bank of City of New York v. United States · Lucas v. Alexander · Susquehanna Power Co. v. State Tax Commission · United States v. Ryerson
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 318 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * an important element in the value of the property [fully paid life insurance] is the use to which it may be put.”
11 later decisions quote this exact passage · from the majority“(a) General. The value of every item of property includible in the gross estate is the fair market value thereof at the time of the decedent's death; * * * The fair market value is the price at which the property would change hands between a willing buyer and a willing seller, neither being under any compulsion to buy or to sell. * * * All relevant facts and elements of value as of the applicable valuation date should be considered in every case. * * * "(c) Stocks and bonds. (1) The value of stocks and bonds, within the meaning of the Internal Revenue Code, is the fair market value per share or bond on the applicable valuation date. * * * "(6) If actual sales or bona fide bid and asked prices are not available, then, in the case of corporate or other bonds, the value is to be arrived at by giving consideration to the soundness of the security, the interest yield, the date of maturity, and other relevant factors * * * "(7) In cases in which it is established that the value per bond or share of any security determined on the basis of selling or bid and asked prices as provided in this paragraph does not reflect the fair market value thereof, then some reasonable modification of such basis or other relevant facts and elements of value shall be considered in determining fair market value.”
4 later decisions quote this exact passage · from the majority“cost * * * is the only suggested criterion which reflects the value * * *. Cost in this situation is not market price in the normal sense of the term. But the absence of market price is no barrier to valuation. * * * Accordingly, the problem here involves an interpretation of `value' in § 506 unaided by an interpretative regulation.”
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.