Merrill v. Fahs’s Empirical Analysis
324 U.S. 308 · 1945
Citation profile
120 federal appellate · 6 district · 15 state decisions
How this case has been cited
Cited by 273 later decisions (11 by the Supreme Court) — most recently May 2019 · most notably United States v. Davis (1962), Harris v. Commissioner (1950)
120 federal appellate · 6 district · 15 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
reviewedFahs v. Merrill (from Fifth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1002
Relies on Sanford's Estate v. Commissioner of Internal Revenue · Commissioner v. Wemyss · Humes v. United States · Taft 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 273 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where property is transferred for less than an adequate and full consideration in money or money’s worth, then the amount by which the value of the property exceeded the value of the consideration shall be deemed a gift and shall be included in computing the amount of gifts made during the calendar year.”
4 later decisions quote this exact passage · from the majority““Correlation of the gift tax and the estate tax still requires legislative intervention, [citations] But to interpret the same phrases in the two taxes concerning the same subject matter in different ways where obvious reasons do not compel divergent treatment is to introduce another and needless complexity into this already irksome situation.” Id. at 313 , 65 S.Ct. at 657.”
3 later decisions quote this exact passage · from the majority“every reason for giving the same words in the gift tax the same reading.”
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.