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← 45 BTA 146 - Ayer v. Commissioner

Ayer v. Commissioner’s Empirical Analysis

1941

Citation profile

23
cited by 23 later decisions
January 1970
most recently cited

1 federal appellate ·

Relationships

Relies on Helvering v. Clifford · Helvering v. Fuller · Thorp v. Lund · Coolidge v. Loring · Black v. Commissioner

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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “* * * Where the grantor has stripped himself of all command over the income for an indefinite period, and in all probability, under the terms of the trust instrument, will never regain beneficial ownership of the corpus, there seems to be no statutory basis for treating the income as that of the grantor under Section 22 (a) merely because he has made himself trustee with broad power in that capacity to manage the trust estate.”
    1 later decision quote this exact passage
  2. “in the discretion of the grantor, either alone or in conjunction with any person not having a substantial adverse interest in the disposition of the part of the income in question.”
    1 later decision quote this exact passage
  3. “may at once pay any or all of the principal or income to herself”
    1 later decision 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.