Sid W. Richardson Foundation v. United States’s Empirical Analysis
430 F.2d 710 · 1970
Citation profile
6 federal appellate · 2 district ·
Relationships
Relies on National Carbide Corporation v. Commissioner of Internal Revenue · Territo v. United States · Magenau v. Aetna Freight Lines, Inc. · United States v. Garbutt Oil Co. · Real Estate - Land Title & Trust Co. 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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““All grounds upon which a taxpayer relies must be stated in the original claim for refund so as to apprise the Commissioner of what to look into; the Commissioner can take the claim at its face value and examine only those points to which his attention is necessarily directed. Anything not raised at that time cannot be raised later in a suit for refund.””
1 later decision quote this exact passage · from the majority“Thus, to qualify for the charitable deduction, the amount here in question must have been (1) part of the Estate’s gross income, and (2) pursuant to the terms of the governing instrument (here the Will) must have been (3) paid or permanently set aside or properly designated to be used exclusively for legitimate charitable purposes.”
1 later decision 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.