Heard v. Commissioner’s Empirical Analysis
1963
Citation profile
2 federal appellate ·
How this case has been cited
Cited by 11 later decisions — most recently February 1995
2 federal appellate ·
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
Relies on Commissioner of Internal Revenue v. Glenshaw Glass Company · Lynch v. United States · Helvering v. Winmill · United States v. Stewart · White v. United States
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 11 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. **«-**-» “(d) Employees’ annuities.— “(1) Employee’s contributions recoverable in 3 years, — Where— “ (A) part of the consideration for an annuity, endowment, or life insurance contract is contributed by the employer, and “(B) during the 3-year period beginning on the date (whether or not before January 1,1954) on which an amount is first received under the contract as an annuity, the aggregate amount receivable by the employee under the terms of the contract is equal to or greater than the consideration for the contract contributed by the employee, then all amounts received as an annuity under the contract shall be excluded from gross income until there has been so excluded (under this paragraph and prior income tax laws) an amount equal to the consideration for the contract contributed by the employee. Thereafter all amounts so received under the contract shall be included in gross income.””
2 later decisions quote this exact passage““The petitioner contends that the Congress did not intend to tax civil service retirement annuities. There is no indication in the original Retirement Act, which was enacted in 1920, that such was the intent. The Revenue Act of 1918, 40 Stat. 1057 , then in effect, defined gross income as ‘gain or profits and income derived from any source whatever.’ Sec. 213(a). The courts have construed the taxing acts as applying to all gains except those specifically exempted.””
2 later decisions 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.