United States v. Estate of Grace’s Empirical Analysis
1969
Citation profile
89 federal appellate · 6 district · 1 state decisions
How this case has been cited
Cited by 258 later decisions (5 by the Supreme Court) — most recently April 2020 · most notably United States v. Byrum (1972), Estate of Bischoff v. Commissioner (1977)
89 federal appellate · 6 district · 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. § 2036 · 26 U.S.C. § 2038 · 26 U.S.C. § 811
Relies on Rodriquez v. United States · Spiegel's Estate v. Commissioner of Internal Revenue · Helvering v. City Bank Farmers Trust Co. · Spiegel's Estate v. Commissioner of Internal Revenue · Orvis v. Higgins
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 258 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“transfers which leave the transferor a significant interest in or control over the property transferred during his lifetime.”
20 later decisions quote this exact passage · from the majority“A. General Rule. — The value of the gross estate shall include the value 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— (1) the possession or enjoyment of, or the right to the income from, the property, or (2) 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.”
6 later decisions quote this exact passage · from the dissent“Rather, we hold that application of the reciprocal trust doctrine requires only that the trusts be interrelated, and that the arrangement, to the extent of mutual value, leaves the settlors in approximately the same economic position as they would have been in had they created trusts naming themselves as life beneficiaries.”
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.