Commissioner of Internal Revenue v. Disston’s Empirical Analysis
325 U.S. 442 · 1945
Citation profile
154 federal appellate · 21 district ·
How this case has been cited
Cited by 324 later decisions — most recently July 2003 · most notably Bingham's Trust v. Commissioner of Internal Revenue (1945), Commissioner of Internal Revenue v. Holmes' Estate (1946)
154 federal appellate · 21 district ·
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 Third Circuit Court of Appeals)
Relationships
Relies on New Colonial Ice Co. v. Helvering · United States v. Pelzer · Fondren v. Commissioner · Ryerson v. United States
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 324 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * In the absence of some indication from the face of the trust or surrounding circumstances that a steady flow of some ascertainable portion of income to the minor would be required, there is no basis for a conclusion that there is a gift of anything other than for the future. The taxpayer claiming the exclusion must assume the burden of showing that the value of what he claims is other than a future interest. * * ””
8 later decisions quote this exact passage · from the majority““ ‘Future interests’ is a legal term, and includes reversions, remainder, 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.” Treasury Regulations of Gift Tax, § 25.-2503-3.”
7 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.