Heyen v. United States’s Empirical Analysis
945 F.2d 359 · 1991
Citation profile
21 federal appellate · 12 district · 1 state decisions
How this case has been cited
Cited by 56 later decisions — most recently October 2018 · most notably Clark v. Haas Group, Inc. (1992), Walter L. Gross, Jr. and Barbara H. Gross v. Commissioner of Internal Revenue
21 federal appellate · 12 district · 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. § 2501 · 26 U.S.C. § 2512 · 26 U.S.C. § 6653
Relies on United States v. Boyle · United States v. Radio Television News Directors Ass'n · Smith v. Crouse · Stoltzfus v. United States · Commissioner v. Wemyss
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he application of the tax is based on the objective facts of the transfer and the circumstances under which it is made.”
3 later decisions quote this exact passage · from the majority“substance over form analysis applies to gift tax, as well as to income tax, cases”
3 later decisions quote this exact passage · from the majority“The required state of mind is one which, if translated into action, is well calculated to cheat or deceive the government.”
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.