United States v. Pyne’s Empirical Analysis
313 U.S. 127 · 1941
Citation profile
74 federal appellate · 3 district · 3 state decisions
How this case has been cited
Cited by 151 later decisions (14 by the Supreme Court) — most recently June 1988 · most notably United States v. Gilmore (1963), Commissioner of Internal Revenue v. P Groetzinger (1987)
74 federal appellate · 3 district · 3 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 Flint v. Stone Tracy Co. · Higgins v. Commissioner · Von Baumbach v. Sargent Land Co. · McCoach v. Minehill & Schuylkill Haven Railroad · Zonne v. Minneapolis Syndicate
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 151 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Nor can the judgment of the Court of Claims be supported by that court’s statement that the executors were engaged ‘in the business of conserving the estate and protecting its income. ’ Such activities are the traditional duty of executors. Executors who engage actively in trade and business are the exception and not the rule. Rather obviously, there could be clear cases where executors ‘ carry on . . . busi ness’ by continuing to operate a store, a factory or some other well known, well marked type of business activity. But in the absence of evidence showing activities coming within the general acceptation of the concept of carrying on a trade or business, it cannot be said as a matter of law that an executor comes into this category merely because he conserves the estate by marshalling and gathering the assets as a mere conduit for ultimate distribution. And determination of what constitutes ‘ carrying on . . . business’ under the Revenue Act does not depend upon the size of the estate or the number of people whose services are required in order properly to conserve it.””
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.