VIEIRA, EX PARTE LUCAS v. the State of Texas

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• defining personal property as “[a]ny movable or intangible thing that is subject to ownership and not classified as real property”
• describing the scope of the gift tax to be analogous in breadth to the definition of gross income contained in section 61
• referring to the “broad sweep of the tax imposed by [section] 2501”
• for federal gift tax purposes the use of money “is itself a legally protectible property interest”
• detrimental reliance by taxpayer on IRS’ prior position did not preclude IRS from asserting different position
• commissioner may change an earlier interpretation and, for the first time, construe gift tax statutes to tax the value of the use of money

Source: CourtListener parenthetical corpus (CC0).