Smith v. Shaughnessy’s Empirical Analysis
318 U.S. 176 · 1943
Citation profile
142 federal appellate · 6 district · 33 state decisions
How this case has been cited
Cited by 363 later decisions (24 by the Supreme Court) — most recently June 2020 · most notably John Kelley Co. v. Commissioner (1946), Lusthaus v. Commissioner (1946)
142 federal appellate · 6 district · 33 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
reviewedthe decision below (from Second Circuit Court of Appeals)
Relationships
Relies on Helvering v. Hallock · Sanford's Estate v. Commissioner of Internal Revenue · Heiner v. Donnan · Burnet v. Guggenheim · Untermyer v. Anderson
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 363 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The language of the gift tax statute, 'property . . . real or personal, tangible or intangible,' is broad enough to include property, however conceptual or contingent.”
9 later decisions quote this exact passage · from the majority“The separable interests transferred are not gifts to the extent that power remains to revoke the trust or recapture the property represented by any of them[.]”
5 later decisions quote this exact passage · from the majority“whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible.”
4 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.