Schatten v. United States’s Empirical Analysis
746 F.2d 319 · 1984
Citation profile
18 federal appellate · 1 state decisions
How this case has been cited
Cited by 38 later decisions — most recently February 2001 · most notably Hoover v. Commissioner (1996), Richardson v. Commissioner (1997)
18 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
Applies 26 U.S.C. § 71
Relies on Blanton v. General Electric Credit Corp. · Lyon v. California · Commissioner of Internal Revenue v. Carl L. Danielson and Pauline S. Danielson, Commissioner Ofinternal Revenue v. Helen P. Sherman, Commissioner Ofinternal Revenue v. Estate of Jacob F. Schaffner, Deceased, Elizabeth Schaffner and Erwin Marsch, Executors, and Elizabeth Schaffner, Commissionerof Internal Revenue v. Hugh E. McLennan and Katherine McLennan · Spector v. Commissioner · Beard 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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'proof which in an action between the parties to the agreement would be admissible to alter the construction or to show its unenforceability because of mistake, undue influence, fraud or duress.'”
3 later decisions quote this exact passage · from the majority“First, allowing a party collaterally to attack a divorce settlement agreement years after it has been entered into would nullify the predictability of tax consequences that parties in divorce situations are seeking to achieve.... Second, the tax consequences of structuring a divorce settlement agreement in a particular way obviously affect the terms of the agreement. If [either party] is in effect permitted to alter the tax consequences that [they] bargained for, then [they] will have succeeded in unilaterally reforming the agreement to [their] benefit. Third, ... [allowing the attack] could well require the Commissioner to litigate the factual circumstances underlying countless divorce settlement agreements. Moreover, if it were held in some cases that a spouse, contrary to the terms of a settlement agreement, was receiving money as part of a property settlement rather than as alimony [for example], then additional litigation might ensue between the Commissioner and the other spouse who had been taking the deductions.”
2 later decisions quote this exact passage · from the majority“[w]here parties to a divorce settlement agreement are represented by counsel, a party may collaterally attack the plain language of the agreement in order to obtain a tax advantage only by showing mistake, undue influence, fraud or duress.”
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.