Helvering v. Stuart’s Empirical Analysis
317 U.S. 154 · 1942
Citation profile
387 federal appellate · 24 district · 20 state decisions
How this case has been cited
Cited by 907 later decisions (36 by the Supreme Court) — most recently November 2019 · most notably Mississippi Band of Choctaw Indians v. Holyfield (1989), Sears, Roebuck & Co. v. Stiffel Co. (1964)
387 federal appellate · 24 district · 20 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
reviewedStuart v. Commissioner (from Seventh Circuit Court of Appeals)
Relationships
Relies on Railroad Commission v. Pullman Co. · Hormel v. Helvering · West v. American Telephone & Telegraph Co. · Helvering v. Clifford · Helvering v. Horst
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 907 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Once rights are obtained by local law, whatever they may be called, these rights are subject to the federal definition of taxability.”
18 later decisions quote this exact passage · from the majority“Economic gain realized or realizable by the taxpayer is necessary to produce a taxable income under our statutory scheme. That gain need not be collected by the taxpayer. He may give away the right to receive it as was done in Helvering v. Horst, 311 U.S. 112 , 61 S.Ct. 144, 85 L.Ed. 75, Helvering v. Eubank, 311 U.S. 122 , 125, 61 S. Ct. 149, 150, 85 L.Ed. 81, and Harrison v. Schaffner, 312 U.S. 579 , 61 S.Ct. 759, 85 L.Ed. 1055. But the donor nevertheless had the `use [realization] of his economic gain.' 311 U.S. at 117, 61 S. Ct. at page [144], 147. In none of the cases had the taxpayer really disposed of the res which produced the income.”
5 later decisions quote this exact passage · from the majority““(a) Where any part of the income of a trust— “(1) is, or in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income may be, held or accumulated for future distribution to the grantor; or “(2) may, in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income, be distributed to the grantor; or “(3) is, or in the discretion of the grantor or of any person not having a substantial adverse interest in the disposition of such part of the income may be, applied to the payment of premiums upon policies of insurance on the life of the grantor (except policies of insurance irrevocably payable for the purposes and in the manner specified in section 23 (o), relating to the so-called ‘charitable contribution’ deduction); th u- such part of the income of the trust shall be included in co «puting the net income of the grantor. “(b) As used in this section, the term ‘in the discretion of the grantor’ means ‘in the discretion of the grantor, either alone or in conjunction with any person not having a substantial adverse interest in the disposition of the part of the income in question’.””
3 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.