United States v. O'MALLEY’s Empirical Analysis
1966
Citation profile
77 federal appellate · 9 district · 4 state decisions
How this case has been cited
Cited by 203 later decisions (5 by the Supreme Court) — most recently June 2019 · most notably United States v. Byrum (1972), Estate of Bongard v. Comm'r (2005)
77 federal appellate · 9 district · 4 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.
Appellate journey
reviewedO'Malley v. United States (from Seventh Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 2036
Relies on Helvering v. Hallock · Stevens v. Marks · May v. Heiner · Spiegel's Estate v. Commissioner of Internal Revenue · Spiegel's Estate v. Commissioner of Internal Revenue
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 203 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“legislative policy of subjecting to tax all property which has been the subject of an incomplete inter vivos transfer.”
7 later decisions quote this exact passage · from the majority“the right ... to designate the persons who shall possess or enjoy the property or the income therefrom.”
3 later decisions quote this exact passage · from the majority“The value of the gross estate of the decedent shall be determined by including the value at the time of his death of all property . To the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise— under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death . . . the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom .”
2 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.