Lockheed Martin Corporation Martin Marietta Corporation Martin Marietta Technologies Inc v. United States’s Empirical Analysis
210 F.3d 1366 · 2000
Citation profile
5 federal appellate · 1 district ·
How this case has been cited
Cited by 47 later decisions — most recently May 2024 · most notably Stone Container Corporation Stone Container International Stone Container Savannah River Pulp Paper v. United States (2000), Computervision Corporation v. United States (2006)
5 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. § 41 · 26 U.S.C. § 7422
Relies on United States v. Winstar Corp. · Union Pacific Railroad v. United States · Winstar Corporation Fsb v. United States · Vaupel Textilmaschinen Kg v. Meccanica Euro Italia Spa · Burlington Northern Inc. v. United States
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“give adequate notice to the [IRS] of the nature of the claim and the specific facts upon which it is predicated, thereby permitting an administrative investigation and determination”
3 later decisions quote this exact passage · from the majority“must set forth in detail each ground upon which a credit or refund is claimed and facts sufficient to apprise the Commissioner of the exact basis thereof.”
2 later decisions quote this exact passage · from the majority“We similarly reject the argument that the determination whether Lockheed Martin retained “substantial rights” to its research can be found by reference to export control laws and top secret classifications; they are also irrelevant because they are outside of the research agreements. The determination whether Lockheed Martin retained “substantial rights” must be made by reference to the ... contracts alone. The regulation’s focus on the taxpayer’s right under the research agreements makes it clear that the determination whether the taxpayer had the right to use the results of its research without paying for that right must be determined by reference to the research agreements.”
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.