Waller v. Commissioner’s Empirical Analysis
1963
Citation profile
2 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 33 later decisions — most recently June 2017 · most notably Southern Pacific Transp. Co. v. Commissioner (1980), Skripak v. Commissioner (1985)
2 federal appellate · 1 district · 2 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. § 170 · 26 U.S.C. § 72
Relies on Gregory v. Helvering · Burnet v. Logan · Better Business Bureau of Washington, D. C., Inc. v. United States · Nicol v. Ames · Shomaker v. Commissioner
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General Rule for Annuities: Except as otherwise provided in this chapter, gross income includes any amount received as an annuity (whether for a period certain or during one or more lives) under an annuity, endowment, or life insurance contract. (b) Exclusion Ratio: Gross income does not include that part of any amount received as an annuity under an annuity, endowment, or life insurance contract which bears the same ratio to such amount as the investment in the contract (as of the annuity starting date) bears to the expected return under the contract (as of such date). * * *”
1 later decision quote this exact passage
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.