United States v. Stapf’s Empirical Analysis

Citation profile

164 federal appellate · 12 district · 18 state decisions

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

1. “[T]he primary thrust ... is to extend to taxpayers in common law states the advantages of 'estate splitting' otherwise available only in community property states.”

   12 later decisions quote this exact passage · from the majority
   e.g. Estate of Reno v. Commissioner · Estate of William L. Reno, Jr. Barbara G. Reno v. Commissioner of Internal Revenue, Virginia Bar Association, Amicus Curiae

2. “General rule — Where, on the lapse of time, on the occurrence of an event or contingen cy, or on the failure of an event or contingency to occur, an interest passing to the surviving spouse will terminate or fail, no deduction shall be allowed under this section with respect to such interest— (A) if an interest in such property passes or has passed (for less than an adequate and full consideration in money or money’s worth) from the decedent to any person other than such surviving spouse (or the estate of such spouse); and (B) if by reason of such passing such person (or his heirs or assigns) may possess or enjoy any part of such property after such termination or failure of the interest so passing to the surviving spouse;”

   5 later decisions quote this exact passage · from the majority
   e.g. Estate of Mittleman v. Commissioner · Estate of Glover v. Comm'r

3. “Allowance of marital deduction. — For purposes of the tax imposed by section 2001, the value of the taxable estate shall, except as limited by subsections (b), (c), and (d), be determined by deducting from the value of the gross estate an amount equal to the value of any interest in property which passes or has passed from the decedent to his surviving spouse, but only to the extent that such interest is included in determining the value of the gross estate.”

   5 later decisions quote this exact passage · from the majority
   e.g. Estate of Mittleman v. Commissioner · Colwell v. United States