Rollman v. United States’s Empirical Analysis

Citation profile

2 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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Section 2503 nowhere explicitly refers to trusts; it covers the whole gamut of gifts. In this context, we must conclude, as did the Third Circuit in Commissioner [of Internal Revenue] v. Herr, supra, that `property' as used in Section 2503(c) is not equivalent to `corpus'. Since Section 2503 applies to all forms of gifts, it covers a transfer of property in which the property itself is income, viz., an assignment of rents. Income rights may be productive of income, e. g., interest on an overdue installment, interest on income after receipt, or an increment upon the investment of income received.”

   1 later decision quote this exact passage
   e.g. Commissioner of Internal Revenue v. Thebaut

2. “(1) may be expended by, or for the benefit of, the donee before his attaining the age of 21 years, and (2) will to the extent not so expended— (A) pass to the donee on his attaining the age of 21 years, and (B) in the event the donee dies before attaining the age of 21 years, be payable to the estate of the donee or as he may appoint under a general power of appointment as defined in section 2514(c).”

   1 later decision quote this exact passage
   e.g. Estate of Levine v. Commissioner

3. “No part of [an income interest] * * * shall be considered a gift of a future interest * * * if [the income interest] and income therefrom —”

   1 later decision quote this exact passage
   e.g. Commissioner of Internal Revenue v. Thebaut