Milner v. Commissioner’s Empirical Analysis

Citation profile

1 federal appellate · 1 district ·

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

1. ““They [the taxpayer petitioners] also oppose taxation on the further ground that under the settlement of the will contest the property never passed to decfedent but passed directly by devise or inheritance from the estate of Gustrine Key'Milner to the trustees for the beneficiaries named in the trust, and that the decedent, consequently owning only a life estate in the property, was not the grantor of the property within the statute and no part of the property passed at or by reason of her death. They insist that the.trust instrument was a mere means used to give effect to the settlement agreement and that, whatever the decedent received was received by her coupled with and subject to the trust.” and the court held:”

   1 later decision quote this exact passage
   e.g. Reed's Estate v. Commissioner

2. ““ * * * In view of our conclusion that the decedent did not make a transfer of any interest in property within the meaning of section 813(c), it is unnecessary to consider the contentions of the respondent that the purported transfer of April 13, 1929, was made by the decedent in contemplation of death, or that it constituted a transfer to take effect in possession or enjoyment at or after her death.””

   1 later decision quote this exact passage
   e.g. Reed's Estate v. Commissioner

3. “entered upon a real controversy regularly submitted for determination.”

   1 later decision quote this exact passage
   e.g. Estate of William O. Burton v. Commissioner