Weigel v. Commissioner’s Empirical Analysis

Citation profile

5 federal appellate ·

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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““§ 22. Gross income * * * * * * “(b) Exclusions from gross income. The following items shall not be included in gross income and shall be exempt from taxation under this title [chapter] : ^ ^ ^ “(3) Gifts, bequests, and devises. The value of property acquired by gift, bequest, devise, or inheritance (but the income from such property shall be included in gross income)”. “Supplement E — Estates And Trusts “§ 161. Imposition of tax “(a) Application of tax. The taxes imposed by this title [chapter] upon individuals shall apply to the income of estates or of any kind of property held in trust, including— “(1) Income accumulated in trust for the benefit of unborn or unascertained persons or persons with contingent interests, and income accumulated or held for future distribution under the terms of the will or trust; “(2) Income which is to be distributed currently by the fiduciary to the beneficiaries, and income collected by a guardian of an infant which is to be held or distributed as the court may direct; “(3) Income received by estates of deceased persons during the period of administration or settlement of the estate;, and “(4) Income which, in the discretion of the fiduciary, may be either distributed to the beneficiaries or accumulated. “(b) Computation and payment. The tax shall be computed upon the net income of the estate or trust, and shall be paid by the fiduciary, except as provided in section 166 (relating to revocable trusts) and section 167 (relating to income for ”

   1 later decision quote this exact passage · from the majority
   e.g. Frazer v. Driscoll