Fondren v. Commissioner’s Empirical Analysis
324 U.S. 18 · 1945
Citation profile
136 federal appellate · 11 district · 3 state decisions
How this case has been cited
Cited by 300 later decisions (2 by the Supreme Court) — most recently December 2019 · most notably Bingham's Trust v. Commissioner of Internal Revenue (1945), Commissioner of Internal Revenue v. Disston (1945)
136 federal appellate · 11 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.
Appellate journey
reviewedFondren v. Commissioner (from Fifth Circuit Court of Appeals)
Relationships
Relies on United States v. Pelzer · Helvering v. Hutchings · Ryerson v. United States · Taylor v. Commissioner
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 300 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Under these decisions it is not enough to bring the exclusion into force that the donee has vested rights. In addition he must have the right presently to use, possess or enjoy the property. * * * The question is of time, not when title vests, but when enjoyment begins. Whatever puts the barrier of a substantial period between the will of the beneficiary or donee now to enjoy what has been given him and that enjoyment makes the gift one of a future interest within the meaning of the regulation.””
12 later decisions quote this exact passage · from the majority“`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 commence in use, possession, or enjoyment at some future date or time.”
10 later decisions quote this exact passage · from the majority““The first $3,000 in value of gifts (other than of future interests in property) made to any person by the donor during any calendar year. * * * ””
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.