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← 44 TC 382 - Perlmutter v. Commissioner

Perlmutter v. Commissioner’s Empirical Analysis

1965

Citation profile

117
cited by 117 later decisions
1
cited 1 times by the Supreme Court
1
states following
September 2019
most recently cited

8 federal appellate · 1 state decisions

How this case has been cited

Cited by 117 later decisions (1 by the Supreme Court) — most recently September 2019 · most notably Commissioner of Internal Revenue v. Idaho Power Company (1974), Henry Schwartz Corp. v. Commissioner (1973)

8 federal appellate · 1 state decisions

450196519701980199020002010decided

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. § 6212

Relies on Stearns Co of Boston Mass v. United States · Wichita Terminal Elevator Co. v. Commissioner · Wichita Terminal Elevator Co. v. Commissioner · Olsen v. Helvering · Luna v. Commissioner

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

  1. “There are no fixed rules or exact standards for determining what constitutes reasonable compensation, for each case must be resolved on its own particular facts and circumstances.”
    2 later decisions quote this exact passage
  2. “such power to so redelegate is prohibited or restricted by proper order or directive.”
    2 later decisions quote this exact passage
  3. “special combination of two or more persons, where in some specific venture a profit is jointly sought without any actual partnership or corporate designation,”
    1 later decision quote this exact passage

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.