Edward Rollert Residuary Trust Genesee Merchants Bank and Trust Company v. Commissioner of Internal Revenue’s Empirical Analysis
752 F.2d 1128 · 1985
Citation profile
3 federal appellate · 1 district ·
How this case has been cited
Cited by 37 later decisions — most recently March 2016 · most notably Norfolk Southern Corp. v. Commissioner (1995), Village of Gambell v. Hodel (1985)
3 federal appellate · 1 district ·
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. § 661 · 26 U.S.C. § 691
Relies on HCSC-Laundry v. United States · Smith v. Westchester County Bar Ass'n · Commissioner of Internal Revenue v. Linde · O'Daniel's Estate v. Commissioner of Internal Revenue · Rollert Residuary Trust 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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is a basic rule of statutory construction that a specific statute controls over a general statute. HCSC-Laundry v. United States, 450 U.S. 1 , 6, 101 S.Ct. 836, 838-39, 67 L.Ed.2d 1 (1981). If we were to hold that the more general statute controls over the specific one, we would effectively eliminate the specific statute.”
1 later decision quote this exact passage“who acquires from the decedent the right to receive the amount by bequest, devise, or inheritance, if the amount is received after a distribution by the decedent's estate of such right.”
1 later decision quote this exact passage · from the dissente.g. Coleman v. Comm'r
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.