Bristol v. Commissioner’s Empirical Analysis

Citation profile

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.

1. ““Art. 8. Transfers for a consideration in money or money’s worth.— Transfers reached by the statute are not confined to those only which, being without a valuable consideration, accord with the common law concept of gifts, but embrace as well sales, exchanges, and other dis-positipns of property for a consideration in money or money’s worth to the extent that the value of the property transferred by the donor exceeds the value of the consideration given therefor. However, a sale, exchange, or other transfer of property made in the ordinary course of business (a transaction which is bona fide, at arm’s length, and free from any donative intent), will be considered as made for an adequate and full consideration in money or money’s worth. A consideration not reducible to a money value, as love and affection,promise of marriage, etc., is to be wholly .disregarded, and the entire yalue of the property transferred'constitutes the amount of the gift.””

   1 later decision quote this exact passage
   e.g. Merrill v. Fahs

2. “shall not be considered to any extent a consideration 'in money or money's worth.'”

   1 later decision quote this exact passage
   e.g. Jones v. Commissioner