United California Bank v. United States’s Empirical Analysis
1978
Citation profile
9 federal appellate · 10 state decisions
How this case has been cited
Cited by 31 later decisions (1 by the Supreme Court) — most recently July 2006 · most notably Estate of Petschek v. Commissioner (1983), Estate of Petschek v. Commissioner (1984)
9 federal appellate · 10 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.
Appellate journey
reviewedUnited California Bank v. United States (from Ninth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 1202
Relies on Penn Central Transportation Co. v. New York City · Freuler v. Helvering · United States v. Foster Lumber Co. · Walter M. Weil and Adele D. Weil v. Commissioner of Internal Revenue
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he beneficiary’s share of the income is considered his property from the moment of its receipt by the estate____ For the purpose of imposing the tax, the Act regards ownership, the right of property in the beneficiary, as equivalent to physical possession. The test of taxability to the beneficiary is not receipt of income, but the present right to receive it.”
2 later decisions quote this exact passage“[I]n exempting charitable entities from tax liability Congress manifested a purpose to insulate all income contributed to charity from taxation. Taxing income en route to charity while temporarily in the possession of an estate is ... inconsistent with the congressional policy to exempt such income from federal taxation altogether ....”
1 later decision quote this exact passage · from the dissent
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.