Robinette v. Helvering’s Empirical Analysis
318 U.S. 184 · 1943
Citation profile
159 federal appellate · 3 district · 2 state decisions
How this case has been cited
Cited by 321 later decisions (13 by the Supreme Court) — most recently November 2021 · most notably Spiegel's Estate v. Commissioner of Internal Revenue (1949), Commissioner v. Wemyss (1945)
159 federal appellate · 3 district · 2 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
reviewedHelvering v. Com'r (from Third Circuit Court of Appeals)
Relationships
Relies on Burnet v. Guggenheim · Humes v. United States · Smith v. Shaughnessy · Helvering v. Com'r
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 321 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The gift tax law itself has no such qualifications. It imposes a tax ‘upon the transfer * * * of property by gift.’ And Treasury Regulations 79, Art. 3, provides that ‘The tax is a primary and personal liability of the donor, is an excise upon his act of making the transfer, is measured by the value of the property passing from the donor, and attaches regardless of the fact that the identity of the donee may not then be known or ascertainable.’ ””
4 later decisions quote this exact passage · from the majority“. a sale, exchange, or other transfer of property made in the ordinary course of business (a transaction which is bona fide, at arm’s length, and free from any donative intent), will be considered as made for an adequate and full consideration in money or money’s worth.”
4 later decisions quote this exact passage · from the majority“reach every kind and type of transfer by gift.”
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.