Hart v. Commissioner’s Empirical Analysis
54 F.2d 848 · 1932
Citation profile
27 federal appellate · 3 district · 3 state decisions
How this case has been cited
Cited by 66 later decisions (3 by the Supreme Court) — most recently June 2017 · most notably Don Williams Company v. Commissioner of Internal Revenue (1977), Heiner v. Mellon (1938)
27 federal appellate · 3 district · 3 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
Applies 26 U.S.C. § 931 · 26 U.S.C. § 955
Relies on United States v. Mitchell · Eckert v. Burnet · Osterloh v. Lucas · Ferguson v. Forstmann · Fidelity-Philadelphia Trust Co. 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 66 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the note may never be paid, and if it is not paid, 'the taxpayer has parted with nothing more than his promise to pay.'”
6 later decisions quote this exact passage · from the majority“clothed with the characteristics of a trust”
3 later decisions quote this exact passage · from the majority“(1) Income accumulated in trust for the benefit of unborn or unascertained persons or persons with contingent interests, and income accumulated or held for future distribution under the terms of the will or trust; * ******”
2 later decisions 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.