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← 48 TC 271 - Talbott v. Commissioner

Talbott v. Commissioner’s Empirical Analysis

1967

Citation profile

7
cited by 7 later decisions
June 1989
most recently cited

2 federal appellate ·

How this case has been cited

Cited by 7 later decisions — most recently June 1989

2 federal appellate ·

30196719701980decided

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 Crooks v. Harrelson · Helvering v. Stockholms Enskilda Bank · United States v. Olympic Radio & Television, Inc. · Smith v. United States · Commissioner of Internal Revenue v. Estate of Ellis Branson Ridgway, Deceased, Craig Sawyer Ridgway and Ellis Branson Ridgway, Jr., Executors

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

  1. “§ 2036. Transfers with retained life estate (a) General rule. — The value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money's worth), by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death — (1) the possession or enjoyment of, or the right to the income from, the property, or (2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom. (b) Limitations on application of general rule. — This section shall not apply to a transfer made before March 4, 1931; nor to a transfer made after March 3, 1931, and before June 7, 1932, unless the property transferred would have been includible in the decedent's gross estate by reason of the amendatory language of the joint resolution of March 3, 1931 (46 Stat. 1516).”
    1 later decision quote this exact passage
  2. “the statutory provision does not refer to an absolute or completed transfer of the entire beneficial interest in the conveyed property.”
    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.