Pitner v. United States’s Empirical Analysis
388 F.2d 651 · 1967
Citation profile
31 federal appellate · 4 state decisions
How this case has been cited
Cited by 67 later decisions — most recently November 2012 · most notably Estate of David Smith, Deceased v. Commissioner of Internal Revenue (1975), Shepherd v. Ledford (1998)
31 federal appellate · 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.
Relationships
Applies 26 U.S.C. § 2053 · 26 U.S.C. § 812
Relies on Kirk v. Beard · Ives v. Culton · Dulles v. Johnson · Re Faling Estate
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is not enough that the deduction be allowable under state law. It is necessary as well that the deduction be for an “administrative expense” within the meaning of that term as it is used in the statute, and that the amount sought to be deducted be reasonable under the circumstances. These are both questions of federal law and establish the outside limits for what may be considered allowable deductions under section 2053(a)(2).”
19 later decisions quote this exact passage · from the majority“For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate such amounts ... for administration expenses ... as are allowable by the laws of the jurisdiction, whether within or without the United States, under which the estate is being administered.”
4 later decisions quote this exact passage · from the majority“as are allowable by the laws of the jurisdiction * * * under which the estate is being administered,”
3 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.