Vaughan v. Clauson’s Empirical Analysis

Citation profile

2 federal appellate ·

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

1. ““The construction of the Act, to the effect that Congress was seeking by it to tax only powers of appointment which were without limitation as to potential appointees, — i.e. powers equivalent to ownership,— is supported by the wording of the regulations as they existed from 1918 to 1937. Throughout that period the regulations defined a general power as one to appoint to any person or persons in the discretion of the donee. With the regulation in that form the statutory provision remained unchanged, although there were complete reenactments of the Estate Tax Revenue Acts of 1921, 1924 and 1926, 42 Stat. 277 and 26 U.S.C.A. Int.Rev.Acts, pages 65 et seq., 224 et seq. This is strong. evidence that the long-standing administrative construction interpreted ‘general power of appointment’ in accordance with the intent of Congress.” (Emphasis supplied)”

   1 later decision quote this exact passage · from the majority
   e.g. Henderson v. Rogan