Watson v. United States’s Empirical Analysis
355 F.2d 269 · 1965
Citation profile
1 federal appellate · 1 state decisions
How this case has been cited
Cited by 9 later decisions — most recently June 1982
1 federal appellate · 1 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.
Relationships
Applies 26 U.S.C. § 812 · 26 U.S.C. § 982
Relies on United States v. United States Gypsum Co. · Commissioner of Internal Revenue v. Duberstein D Stanton · Graver Tank & Mfg. Co. v. Linde Air Products Co. · Commissioner of Internal Revenue v. Heininger · Burnet v. Harmel
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In any event, whatever might be said as to the rightness of said definition, it could not be correctly applied to the trust at bar which contains entirely proper personal, private and legitimately selfish elements. And certainly, as of this day and age, that definition cannot be said to accurately describe the Gimbel employees’ foundation. We strongly disagree with the suggestion that the conclusion that the Testamentary Trust was made for exclusively charitable purpose in accordance with § 812(d) was a permissible one under C. I. R. v. Duberstein, 363 U.S. 278 , 80 S.Ct. 1190 , 4 L.Ed.2d 1218 (1960). That conclusion was founded on a similar one in Gimbel which had been made by the appellate court in reversing the lawfully designated fact-finder, the Board of Tax Appeals. With the lapse of time and changed economic conditions the district court’s holding in this appeal is even more clearly wrong than the appellate conclusion in Gimbel upon which it relies. In fairness we note and emphasize that the district judge had no recourse but to follow the then undisturbed Gimbel opinion. It should be noted also that the other decisions named in support of Gimbel, to the extent that they do, are, to say the least, as outmoded as is Gimbel.” On page 271 the Court stated: “From the above stipulated facts it would seem that the Testamentary Trust involved was manifestly not a charitable bequest within the definition of Section 812(d). We are not here dealing with an impoverished class. I”
1 later decision quote this exact passagee.g. Succession of Hyams
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.