Ca 79-3074 William Quarrie Mable Quarrie and Margaret Quarrie Charitable Fund v. Commissioner of Internal Revenue’s Empirical Analysis
Citation profile
1 district · 2 state decisions
How this case has been cited
Cited by 12 later decisions — most recently December 2017
1 district · 2 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. § 4940 · 26 U.S.C. § 507 · 26 U.S.C. § 509
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an organization which— (A) is organized, and at all times thereafter is operated, exclusively for the benefit of, to perform the functions of, or to carry out the purposes of one or more * * * [publicly supported organizations], (B) is operated, supervised, or controlled by or in connection with one or more * * * [publicly supported organizations]; and (C) is not controlled directly or indirectly by one or more disqualified persons * * * other than foundation managers and other than one or more * * * [publicly supported organizations] * * *”
2 later decisions quote this exact passage · from the majority“) is set forth in section 1.509(a)-4(i)(3)(ii), Income Tax Regs. : The activities engaged in for or on behalf of the publicly supported organizations are activities to perform the functions of, or to carry out the purposes of, such organizations, and, but for the involvement of the supporting organization, would normally be engaged in by the publicly supported organizations themselves. The second alternative (referred to as the”
2 later decisions quote this exact passage · from the majority“Private foundations were defined and subjected to significant regulations and controls by the Tax Reform Act of 1969. These reforms were prompted by Congressional concern over widespread abuses of the tax-exempt status of private founda-tions_ Public charities were excepted from private foundation status on the theory that their exposure to public scrutiny and their dependence on public support would keep them from the abuses to which private foundations were subject.”
1 later decision quote this exact passage · from the majoritye.g. Kelsey v. Ray
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.