Messing v. Commissioner’s Empirical Analysis
1967
Citation profile
2 federal appellate · 1 state decisions
How this case has been cited
Cited by 162 later decisions — most recently November 2016 · most notably Buffalo Tool & Die Mfg. Co. v. Commissioner (1980), Estate of Newhouse v. Commissioner (1990)
2 federal appellate · 1 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.
Relationships
Relies on Estate of Cora R. Fitts, Deceased, J. Russel Fitts and Frank E. Tyler, Co-Executors v. Commissioner of Internal Revenue · The Central Trust Company and Albert E. Heekin, Jr., Co-Executors of the Estate of Albert E. Heekin, Deceased v. The United States. Katharine Heekin Herrlinger, James R. Heekin, Jr., and the Central Trust Company, Executors Under the Will of James J. Heekin, Deceased v. The United States. The Central Trust Company, Successor and Trustee Under the Will of Alma R. Heekin, Deceased v. The United States · Commissioner of Internal Revenue v. Marshall · Jacoby v. . Jacoby · United States v. Baker
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 162 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“inherently imprecise and capable of resolution only by a Solomon-like pronouncement.”
19 later decisions quote this exact passage“(b) Exclusion From Gifts. — In the case of gifts (other than gifts of future interesets inproperty) made to any person by the donor during the calendar year 1955 and subsequent calendar years, the first $3,000 of such gifts to such person shall not, for purposes of subsection (a), be included in the total amount of gifts made during such year. * * *”
1 later decision quote this exact passage“a publicly traded stock and a privately traded stock are not, as respondent would have us assume, the same animal distinguished only by the size, frequency, or color of its spots. The essential nature of the beast is different.”
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.