Helvering v. Hutchings’s Empirical Analysis
312 U.S. 393 · 1941
Citation profile
127 federal appellate · 21 district · 7 state decisions
How this case has been cited
Cited by 291 later decisions (13 by the Supreme Court) — most recently August 2015 · most notably United States v. Pelzer (1941), Don Williams Company v. Commissioner of Internal Revenue (1977)
127 federal appellate · 21 district · 7 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
reviewedHutchings v. Commissioner of Internal Revenue (from Fifth Circuit Court of Appeals)
Relationships
Relies on Sanford's Estate v. Commissioner of Internal Revenue · Rasquin v. Humphreys · Rheinstrom v. Commissioner of Internal Revenue · Welch v. Davidson
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 291 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the case of gifts (other than of future interests in property) made to any person by the donor during the calendar year, the first $5,000 of such gifts to such person shall not, for the purposes of subsection (a), be included in the total amount of gifts made during such year.”
3 later decisions quote this exact passage · from the majority“The gift tax provisions are not concerned with mere transfers of legal title to the trustee without surrender by the donor of the economic benefits of ownership and his control over them. A gift to a trustee reserving to the donor the economic benefit of the trust or the power of its disposition, involves no taxable gift. It is only upon the surrender by the donor of the benefit or power reserved to himself that a taxable gift occurs. * * *”
2 later decisions quote this exact passage · from the majority“But for present purposes it is of more importance that in common understanding and in the common use of language a gift is made to him upon whom the donor bestows the benefit of his donation. One does not speak of making a gift to a trust rather than to his children who are its beneficiaries. The reports of the committees of Congress used words in their natural sense and in the sense in which we must take it they were intended to be used in § 504(b) when, in discussing § 501, they spoke of the beneficiary of a gift upon trust as the person to whom the gift is made. * * * [Helvering v. Hutchings, 312 U.S. 393, 396 (1941).]”
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.