United States v. Pelzer’s Empirical Analysis

Citation profile

309 federal appellate · 33 district · 9 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 624 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““The term ‘future interests in property’ refers to any interest or estate, whether vested or contingent, limited to commence -in possession or enjoyment at a future •date.””

   9 later decisions quote this exact passage · from the majority
   e.g. Estate of Herrmann v. Commissioner · Welch v. Paine

2. ““But as we have often had occasion to point out, the revenue laws are to be construed in the light of their general purpose to establish a nationwide scheme of taxation uniform in its application. Hence their provisions are not to be taken as subject to state control or limitation unless the language or necessary implication of the section involved makes its application dependent , on state law. Burnet v. Harmel, 287 U.S. 103 , 110 [ 53 S.Ct. 74 , 77 L.Ed. 199J; Morgan v. Commissioner, 309 U.S. 78 , 81 [ 60 S.Ct. 424 , 84 L.Ed. 585 ].””

   8 later decisions quote this exact passage · from the majority
   e.g. Helvering v. Stuart · United States v. Irvine

3. ““ ‘Future interests’ is a legal term, and includes reversions, remainders, and other interests or estates, whether vested or contingent, and whether or not supported by a particular interest or estate, which are limited) to commerce in use, possession, or enjoyment at some future date or time. * * * ” (Italics ours.)”

   7 later decisions quote this exact passage · from the majority
   e.g. Welch v. Paine · Wisotzkey v. Commissioner