Jacobs v. Commissioner’s Empirical Analysis

Citation profile

28 federal appellate ·

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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The claims which Congress intended to be deducted were actual claims, not theoretical ones.”

   8 later decisions quote this exact passage · from the majority
   e.g. Estate of Sachs v. Commissioner · First National Bank of Pennsylvania v. United States

2. “claims against the estate” were written into the revenue statutes. * * * It was, in our opinion, claims presented and allowed or otherwise determined as valid against the estate and actually paid or to be paid that Congress had in mind, when it provided for the deduction from the gross estate of”

   4 later decisions quote this exact passage · from the majority
   e.g. Estate of Sachs v. Commissioner · Estate of Chesterton v. United States

3. ““(a) [as amended by Section 403(a) of the Revenue Act of 1934] In the case of a citizen or resident of the United States, by deducting from the value of the gross estate— “(1) [as amended by Section 806 of the Revenue Act of 1932] Such amounts — i “(A) for funeral expenses, ‘‘(B) for administration expenses, “(C) for claims against the estate, “(D) for unpaid mortgages upon, or any indebtedness in respect to, property where the value of decedent’s interest therein, undiminished by such mortgage or indebtedness, is included in the value of the gross estate, and “(E) reasonably required and actually expended for the support during the settlement of the estate of those dependent upon the decedent, as are allowed by the laws of the jurisdiction, whether within or without the United States, under which the estate is being administered, but not including any income taxes upon income received after the death of the decedent, or property taxes not accrued before his death, or any estate, succession, legacy, or inheritance taxes. The deduction herein allowed in the case of claims against the estate, unpaid mortgages, or any indebtedness shall, when founded upon a promise or agreement, be limited to the extent that they were contracted bona fide and for an adequate and full consideration in money or money’s worth. * * * “(d) [as amended by Section 804 of the Revenue Act of 1932] * * * For the purposes of this title, a relinquishment or promised relinquishment of dower, curte-sy, or of ”

   3 later decisions quote this exact passage · from the majority
   e.g. Commissioner v. State Street Trust Co. · Commissioner of Internal Rev. v. State Street T. Co.