Ferman v. United States’s Empirical Analysis
1992
Citation profile
4 federal appellate ·
Relationships
Applies 26 U.S.C. § 2057
Relies on United States v. American Trucking Associations · Commissioner of Internal Revenue v. South Texas Lumber Co · Pension Benefit Guaranty Corporation v. RA Gray & Co. · Bob Jones University v. United States · Welch v. Henry
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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) General Rule. — For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate an amount equal to 50 percent of the qualified proceeds of a qualified sale of employer securities. (b) Qualified Sale. — For purposes of this section, the term "qualified sale” means any sale of employer securities by the executor of an estate to— (1) an employee stock ownership plan ... described in section 4975(e)(7), or (2) an eligible worker-owned cooperative (within the meaning of section 1042(c)). (c) Qualified Proceeds. — For purposes of this section— (1) In general. — The term "qualified proceeds" means the amount received by the estate from the sale of employer securities at any time before the date on which the return of the tax imposed by section 2001 is required to be filed (including any extensions). (2) Proceeds from certain securities not qualified. — The term "qualified proceeds" shall not include the proceeds from the sale of any employer securities if such securities were received by the decedent— (A) in a distribution from a plan exempt from tax under section 501(a) which meets the requirements of section 401(a), or (B) as a transfer pursuant to an option or other right to acquire stock to which section 83, 422, 422A, 423, or 424 applies. (d) Written Statement Required.— (1) In general. — No deduction shall be allowed under subsection (a) unless the executor of the estate of the decedent fi”
1 later decision 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.